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Draft Contractor Document: Subject to Continuing Agency Review
Lower Passaic River
Restoration Project
DRAFT
SOURCE CONTROL EARLY ACTION
FOCUSED FEASIBILITY STUDY
PREPARED BY:
Malcolm Pirnie, Inc.
104 Corporate Park Drive
White Plains, NY 10602
FOR:
US Environmental Protection Agency
US Army Corps of Engineers
New Jersey Department of Transportation
June 2007
DRAFT
SOURCE CONTROL EARLY ACTION
FOCUSED FEASIBILITY STUDY
LOWER PASSAIC RIVER RESTORATION PROJECT
Prepared by:
Malcolm Pirnie, Inc.
In conjunction with:
Battelle
HydroQual, Inc.
June 2007
Version 2007/06/08
Draft Contractor Document: Subject to Continuing Agency Review
Draft Contractor Document: Subject to Continuing Agency Review
EXECUTIVE SUMMARY
INTRODUCTION
The Lower Passaic River Restoration Project (“the Study”) is a comprehensive study of
the 17-mile tidal portion of the Passaic River and its watershed. This integrated Study is
being implemented by the U.S. Environmental Protection Agency (USEPA) under the
Superfund Program (the Lower Passaic River is a part of the Diamond Alkali Superfund
Site); by the U.S. Army Corps of Engineers (USACE) and New Jersey Department of
Transportation (NJDOT) under the Water Resources Development Act; and by the U.S.
Fish and Wildlife Service (USFWS), National Oceanic and Atmospheric Administration
(NOAA), and New Jersey Department of Environmental Protection (NJDEP) as Natural
Resource Trustees. The scope of the Study is to gather data needed to make decisions on
remediating contamination in the river to reduce human health and ecological risks,
improve the water quality of the river, improve and create aquatic habitat, improve
human use, and reduce contaminant loading in the Lower Passaic River and the New
York-New Jersey Harbor Estuary.
During the course of the Study, sediments in the lower eight miles of the river were
identified as a major source of contamination to the 17-mile Study Area and to Newark
Bay. Therefore, this Focused Feasibility Study (FFS) was undertaken to evaluate a range
of remedial alternatives that might be implemented as an early action to control that
major source. The Source Control Early Action, if undertaken, would address
contaminated sediments in the lower eight miles of the Passaic River, in order to more
rapidly reduce risks to human health and the environment. The Source Control Early
Action, which would be a final action for the sediments in the lower eight miles, is
intended to take place in the near term, while the comprehensive 17-mile Study is ongoing.
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DESCRIPTION OF THE RIVER
The Lower Passaic River watershed was one of the major centers of the American
industrial revolution, with early manufacturing, particularly cotton mills, developing in
the area around Great Falls in Paterson, New Jersey. In subsequent years, many
industrial operations developed along the banks of the Passaic River, including
manufactured gas plants, paper manufacturing and recycling facilities, chemical
manufacturing facilities, and others that used the river for wastewater disposal. Direct
and indirect discharges from these facilities have impacted the river. Furthermore, the
Lower Passaic River has received direct and indirect municipal discharges from the
middle of the nineteenth century to the present time. Together, these waste streams
(industrial and municipal) discharged many contaminants, including dioxins, petroleum
hydrocarbons, polychlorinated biphenyls (PCB), pesticides, and metals to the Lower
Passaic River.
Today, extremely contaminated surface sediments present high levels of risk to human
heath and the ecosystem. A risk assessment conducted for the FFS concluded that among
adults consuming 40 meals per year of fish from the Lower Passaic River over 30 years,
their risk of developing cancer would be one in one hundred. This risk is greater than
USEPA’s risk range established in the Superfund Program of one in ten thousand to one
in a million. Approximately 65 percent of the human health cancer risk is associated with
the presence of dioxin. Most of the remaining cancer risk (approximately 33 percent) is
from PCB, while all other contaminants combined contribute approximately two percent.
Accordingly, fish consumption advisories have been in place for many years due to
contamination from dioxins and PCB. Similar risks are present for wildlife, although
metals and pesticides cause most of the risk to fish, while dioxin and PCB cause most of
the risks for animals and birds that eat fish.
An important component of the region’s historical development and urbanization was the
deepening of the river to permit commercial navigation into the city of Newark and
farther upriver. Several large dredging projects at the beginning of the twentieth century
established and maintained a navigation channel through more than 15 miles of the river.
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Since the 1940s, there has been little maintenance dredging and none since the early
1980s. Consequently, the river has accumulated substantial sediment deposits
particularly in the lower eight miles, measuring up to 25 feet thick. Less sedimentation
has occurred upstream because of the faster flowing narrower channel. Tidal mixing has
distributed contamination throughout the lower eight miles, as well as upriver and into
Newark Bay and the New York – New Jersey Harbor Estuary.
Sediment contamination is even greater in deeper sediments than at the surface.
Sediment erosion due to the back-and-forth motion of the tides and storm events is most
likely responsible for continuing releases of contaminants from the river bed. As a
fraction of all of the solids sources to the Lower Passaic, resuspension of deeper
sediments comprises about 10 percent of the total annual deposition. However,
resuspension accounts for over 95 percent of the dioxin accumulating in the river bottom,
and at least 40 percent of PCBs, pesticides and mercury accumulating in the river.
The Lower Passaic River is also a major source of contaminants to Newark Bay.
Sediment transport from the Lower Passaic River to Newark Bay delivers the
contaminants found in Newark Bay’s surficial sediments, particularly dioxin. It is
estimated that the Lower Passaic River contributes approximately 10 percent of the
average annual amount of sediment accumulating in Newark Bay, and more than 80
percent of the dioxin accumulating in the Bay. A recent study of dioxin contamination in
New York Harbor (Chaky, 2003) suggests that the Lower Passaic River dioxin signature
can be traced through the entire Harbor. The Lower Passaic River also contributes
approximately 20 percent of the mercury to Newark Bay.
Sediment contamination is not the only problem in the Lower Passaic River. The
communities that line the banks of the Lower Passaic River are prone to flooding.
Development of the banks and the watershed has eliminated vital wetlands and
floodplains, so that flood events pose economic and public safety risks. Finally, the State
of New Jersey has reaffirmed its need for the river’s navigation infrastructure, as its
communities develop plans for use of a restored river in the future. The State’s needs are
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documented in this report and help define the reasonably anticipated future use for the
Lower Passaic River.
REMEDIAL ACTION OBJECTIVES AND TARGET AREAS
Remedial Action Objectives (RAOs) were established to describe what the cleanup is
expected to accomplish, and preliminary remediation goals (PRGs) were developed as
targets for the cleanup to meet in order to protect human health and the environment.
The RAOs are as follows:
•
Reduce cancer risks and non-cancer health hazards for people eating fish and shellfish
from the Lower Passaic River by reducing the concentration of contaminants of
potential concern (COPCs) in fish and shellfish.
•
Reduce the risks to ecological receptors by reducing the concentration of
contaminants of potential ecological concern (COPECs) in fish and shellfish.
•
Reduce the mass of COPCs and COPECs in sediments that are or may become
bioavailable.
•
Remediate the most significant mass of contaminated sediments that may be mobile
(e.g., erosional or unstable sediments) to prevent it from acting as a source of
contaminants to the Lower Passaic River or to Newark Bay and the New York-New
Jersey Harbor Estuary.
Background contaminant contributions to sites should be considered to adequately
understand contaminant sources and establish realistic risk reduction goals. Investigation
of sediment contaminant concentrations in the Upper Passaic River above the Dundee
Dam has revealed the presence of historic and ongoing upstream sources of inorganics,
pesticides, and PCB that are significant in comparison to contaminant concentrations in
the Lower Passaic River. USEPA guidance defines “background” as constituents and
locations that are not influenced by releases from the site and includes both
anthropogenic and naturally derived constituents. The dam physically isolates the
proximal Dundee Lake and other Upper Passaic River sediments from Lower Passaic
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River influences while the Lower Passaic River receives contaminant loads from above
the dam. The proximity of these sediments to the proposed remediation area and
demonstrated geochemical connection to a portion of the Lower Passaic River sediment
contamination strongly argues in favor of their consideration as representative of
“background” for the Lower Passaic River.
A number of human health and ecological risk-based concentrations were considered in
the development of PRGs. The developed risk-based threshold concentrations were
calculated from cancer risks and toxicity for human receptors who potentially consume
between one and 40 meals of fish or shellfish a year from the river and from toxicity to
benthic organism and wildlife. The background concentrations derived from recent
sediment data from above Dundee Dam were found to be above the risk-based thresholds.
Since the Superfund program, generally, does not clean up to concentrations below
natural or anthropogenic background levels (USEPA, 2002b), background concentrations
were selected as PRGs. Table A lists the background concentrations of COPECs and
COPCs, selected as the PRGs.
Table A: Selected PRGs
Contaminant
Copper
Lead
Mercurya
Low Molecular Weight PAHs
High Molecular Weight PAHs
Total PCB
Total DDx
Dieldrin
Chlordane
2,3,7,8-TCDD
Background Concentration (ng/g)
80,000
140,000
720
8,900
65,000
660
91
4.3
92
0.002
(a) All occurrences of mercury are assumed to be methylated for purposes of this evaluation.
The COPC and COPEC concentrations known to exist in the surface sediments of the
lower 8 miles are much greater than these PRGs. For this reason a remedial strategy that
can reduce the concentrations to at least the level of background is necessary to begin to
achieve the RAOs.
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The background levels for many of the contaminants pose unacceptable risks, in part
resulting from continuing contributions from upstream sources. Thus, while the Source
Control Early Action addresses the contaminated sediments of the lower eight miles of
the Passaic River, a separate source control action will need to be implemented above
Dundee Dam to identify and reduce or eliminate those background sources. Such a
separate action might include identifying facilities above the dam with on-going
contributions to the Upper Passaic River, or conducting a track-down program where
samplers are placed further and further upstream until contaminants are tracked back to
specific industrial or municipal sources. Such sources would then be controlled through
federal or State of New Jersey regulatory programs.
To identify distinct areas that, if remediated, may result in the achievement of RAOs, a
series of geospatial and geochemical analyses were conducted. During these analyses,
three target areas were identified for consideration: the Primary Erosional Zone (68
acres), the Primary Inventory Zone (63 acres), and the Area of Focus (650 acres, lower
eight miles). The Primary Erosional Zone is an area of the Lower Passaic River in which
there exists a greater amount of surface area that may erode as compared to other areas of
the river. The Primary Inventory Zone is an area of the Lower Passaic River in which
there exists a relatively greater contaminant inventory (mass) as compared to other areas
of the river. The Area of Focus encompasses the entire (bank-to-bank) river area from
RM0 to RM8.3, which contains elevated COPC and COPEC concentrations in surface
sediment and contaminant inventory that is at risk of being eroded and transported over
time due to high flow events as well as typical flow and tidal conditions.
Future concentrations of COPECs and COPCs in the Lower Passaic River surface
sediments were estimated using an empirical method. The sediment concentration
forecasting supported risk evaluations, which considered the following scenarios: No
Action (including natural recovery), remediating the Primary Erosion Zone, remediating
the Primary Inventory Zone, and remediating the Area of Focus.
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These evaluations of risk, development of PRGs, and estimation of future concentrations
were used to evaluate the benefit of remediating each of the three target areas. Based on
the estimated risk reduction, No Action or the remediation of only the Primary Erosional
Zone and/or the Primary Inventory Zone will not achieve residual risks within the
USEPA risk range of one in ten thousand to one in a million within reasonable time
frames. In addition, sediment concentrations exceeding PRGs have been identified
throughout the Area of Focus and remediating only the Primary Erosion Zone and/or the
Primary Inventory Zone does not address these continuing contaminant sources.
However, remediating the Area of Focus reduces the COPC and COPEC concentrations
in the surface sediments over the long term to the background concentrations that are
introduced to the Lower Passaic River from the Upper Passaic River. Active remediation
of the Area of Focus is also predicted to reduce the human health risk by 95 to 98 percent
(fish versus crab consumption) and the ecological hazard by 78 to 98 percent (species
dependent), which meets the RAOs. It is important to note that regardless of the PRG or
risk levels that need to be achieved, remediating the Area of Focus achieves clean-up of
2,3,7,8-TCDD, which is responsible for about 65 percent of the human health cancer risk,
40 years faster than it would be achieved by No Action. The reduction of other COPCs
and COPECs is also accelerated by the remediation of the Area of Focus. For these
reasons, all active alternatives were developed to remediate the Area of Focus, which
encompasses the fine-grained sediments of the lower eight miles in their entirety.
DEVELOPMENT OF ALTERNATIVES
Available technologies were analyzed in order to develop alternatives for remediating the
sediments of the lower eight miles. Consistent with the intent of an early action,
preference was given to technologies that have been proven in other full-scale remedies
and could be designed and implemented in the near term, without additional lengthy
research. For the in-river aspects of the remediation, remedial technology classes
selected for analysis were dredging (mechanical) and engineered capping (sand and
armor). For management of dredged materials, nearshore confined disposal facilities
(CDF) were selected for analysis, either as the only management solution or in
combination with a local thermal treatment facility.
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In addition to the No Action alternative that the Superfund program requires to be
evaluated, six active alternatives were developed and evaluated:
•
Alternative 1: Removal of Fine Grained Sediment from Area of Focus.
•
Alternative 2: Engineered Capping of Area of Focus.
•
Alternative 3: Engineered Capping of Area of Focus Following Reconstruction of
Federally Authorized Navigation Channel.
•
Alternative 4: Engineered Capping of Area of Focus Following Construction of
Navigation Channel to Accommodate Current Usage.
•
Alternative 5: Engineered Capping of Area of Focus Following Construction of
Navigation Channel to Accommodate Future Usage.
•
Alternative 6: Engineered Capping of Area of Focus Following Construction of
Navigation Channel to Accommodate Future Usage and Removal of Fine Grained
Sediment from Primary Inventory Zone and Primary Erosional Zone.
Following the completion of active remediation in the river, each of these alternatives
relies on monitored natural recovery, with institutional controls, to achieve
protectiveness.. In addition, separate source control actions above Dundee Dam, when
implemented, will shorten the time frame within which the active alternatives achieve
protectiveness.
DETAILED ANALYSIS OF ALTERNATIVES
The Superfund program has established nine criteria for evaluating remedial alternatives.
The first two criteria are threshold criteria that must be met by each alternative: overall
protection of human health and the environment, and compliance with applicable or
relevant and appropriate requirements (ARARs). The next five criteria are primary
balancing criteria upon which the analysis is based: long-term effectiveness and
permanence; reduction of toxicity, mobility or volume through treatment; short-term
effectiveness; implementability; and cost. The No Action alternative and six active
alternatives were evaluated using these seven criteria, with the last two, the modifying
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criteria of state acceptance and community acceptance, left to be evaluated following the
Proposed Plan.
A summary of the comparison of the No Action alternative and the six active remediation
alternatives to the Superfund criteria is included in Table B. A summary of important
quantitative estimates for No Action alternative and the six active alternatives is included
in Table C. A graphical presentation of the costs for the six active alternatives is shown
on Figure A.
All active remediation alternatives rely on natural recovery processes in the river, as well
as continued introduction of relatively cleaner sediments from above the Dundee Dam,
for continued improvement following active remediation of sediments in the lower eight
miles to control that source of contaminants. In contrast to the other alternatives, the No
Action alternative does not require any active measures to address the contaminated
sediment; thus is it technically feasible and would result in comparatively little cost.
However, the No Action alternative would take much longer to achieve remedial action
objectives compared to the active alternatives, and would be ineffective at reducing
toxicity, mobility and volume of contaminated sediments. While active alternatives
would result in rapidly cutting off the source of much contamination to Newark Bay and
its gradual improvement, No Action would allow the continued long-term mobilization of
contaminated sediments to Newark Bay and other areas in the New York – New Jersey
Harbor Estuary. The No Action alternative would not support the reasonably anticipated
future uses of the river for navigation. Finally, the No Action alternative would not meet
RAOs within a reasonable time frame and would thus not be protective of human health
and the environment.
In addition to cost, the major differences among the six active alternatives are related to
the volume of material to be dredged, the final elevation of the remediated surface in
various stretches of the lower eight miles (related to compatibility with future use
objectives), and the extent of engineered capping employed versus backfilling. As shown
on Table B, all active alternatives are considered equivalent for the criteria of Overall
Protection of Human Health and the Environment and Compliance with ARARs. The
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active alternatives can be distinguished from each other for the other five criteria as
follows:
•
Long Term Effectiveness and Permanence: Alternatives 1 and 3 rely most heavily on
backfill (which would not be maintained) following dredging to historically dredged
surfaces, and Alternatives 2 and 4 rely most on engineered capping, which would be
maintained in perpetuity. Dredging followed by backfilling and capping are judged to
have similar adequacy in addressing the contamination in the fine-grained sediments,
and the reliability of both depends on proper design and implementation. However,
the long-term reliability of capping depends heavily on the consistency and
sufficiency of future cap maintenance activities, while the long-term reliability of
backfill placed would not be monitored.
•
Reduction of Toxicity, Mobility, and Volume: the active alternatives have varying
dredging removal volumes that range from 1.2 million cubic yards to 11 million cubic
yards.
•
Short Term Effectiveness: larger removal volumes would have a greater potential for
short term impacts from dredging resuspension and associated construction activities
(see estimated construction durations on Table C).
•
Implementability: the active alternatives are distinguished primarily on the basis of
flooding (considerable flooding increases would occur for Alternatives 2 and 4); also,
certain alternatives would require administrative changes to the navigation channel
authorization (Alternatives 2, 4, 5, and 6).
•
Cost: the active alternatives range in cost from $0.9 billion to $2.3 billion.
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Table B: Summary of Detailed Analysis of Alternatives
Alternative
No Action
Overall Protection of Human
Health and the Environment
Not protective. Natural
recovery processes would
achieve some reduction in risk
from current levels, but human
health and ecological risks
continue to be above acceptable
levels. In addition, the
contaminated sediment load
from the Lower Passaic River to
Newark Bay and the New YorkNew Jersey Harbor Estuary
would continue.
Compliance with ARARs
None of the identified
action-specific or locationspecific ARARs are
applicable to the No Action
alternative.
Alternative 2: Engineered Capping of
Area of Focus
Alternative 4: Engineered Capping of
Area of Focus Following Construction
of Navigation Channel to
Accommodate Current Usage
Alternative 5: Engineered Capping of
Area of Focus Following Construction
of Navigation Channel for Future Use
Alternative 6: Engineered Capping of
Area of Focus Following Construction
of Navigation Channel for Future Use
and Removal of Fine Grained
Sediment from Primary Inventory
Zone and Primary Erosional Zone
Focused Feasibility Study
Lower Passaic River Restoration Project
Protective. Human health risks
are reduced to the risk range.
Substantial ecological
improvements occur in a
substantially shorter period of
time. Institutional controls will
be necessary to protect human
health after remedy is
implemented, during period of
monitored natural recovery.
Control of sources above
Dundee Dam will accelerate
time to reach risk range.
Alternative 1 through 6 will
be designed and carried out
in accordance with
applicable ARARs and
accepted best management
practices.
Reduction of Toxicity, Mobility,
and Volume through Treatment
Cancer risks reduced to 4x10-3 for ingestion of fish
and 3x10-3 for ingestion of crab. For fish
ingestion, HI for adult reduced to 6.8 and child to
31. For crab ingestion, HI for adult reduced to 5.2
and child to 27. Mink HI reduced to 52. Heron HI
reduced to 5.
Cancer risks reduced to 5x10-4 for ingestion of fish
and 4x10-4 for ingestion of crab. For fish
ingestion, HI for adult reduced to 4.7 and child to
22. For crab ingestion, HI for adult reduced to 3.5
and child to 19. Mink HI reduced to 6. Heron HI
reduced to 2.
Alternative 1: Removal of Fine
Grained Sediment from Area of Focus
Alternative 3: Engineered Capping of
Area of Focus Following
Reconstruction of Federally
Authorized Navigation Channel
Long Term Effectiveness and Permanence
Alternative 1 relies exclusively on placement of a
backfill layer to provide a measure of control in
the event that residual contamination poses health
risks. This alternative does not include an
engineered cap, because the intent is for the
contaminated fine-grained sediment to be removed
with the assumption that the underlying lesscontaminated sand material will not erode to any
significant extent. The backfill layer is not
intended to be maintained, in contrast to the
engineered cap in Alternative 2 whose thickness
must be maintained in the long term in order to
ensure protectiveness of contaminant inventory left
underneath.
Alternatives 3, 4, 5, and 6 rely on varying
combinations of backfill and engineered cap,
depending on the amount of contaminated
inventory left after dredging. Of these four
alternatives, Alternative 3 proposes removing the
most fine-grained sediment down to the underlying
sandy layer, while Alternative 4 proposes leaving
behind the most contaminant inventory, so that
Alternative 3 relies most heavily on backfill and
Alternative 4 relies most on engineered capping.
The reliability of both dredging and engineered
caps depends upon proper design and
implementation, while the reliability of capping
also depends on the consistency and sufficiency of
future maintenance.
None
Removal of 11 million cy of
contaminated sediment would
permanently reduce volume of
contaminants in Area of Focus.
Thermal treatment of 1.7 million
cy would irreversibly destroy
contaminants.
Removal of 1.2 million cy of
contaminated sediment would
permanently reduce volume of
contaminants in Area of Focus.
Thermal treatment of 1.2 million
cy would irreversibly destroy
contaminants.
Removal of 7.1 million cy of
contaminated sediment would
permanently reduce volume of
contaminants in Area of Focus.
Thermal treatment of 1.7 million
cy would irreversibly destroy
contaminants.
Removal of 3.2 million cy of
contaminated sediment would
permanently reduce volume of
contaminants in Area of Focus.
Thermal treatment of 1.7 million
cy would irreversibly destroy
contaminants.
Removal of 6.3 million cy of
contaminated sediment would
permanently reduce volume of
contaminants in Area of Focus.
Thermal treatment of 1.7 million
cy would irreversibly destroy
contaminants.
Removal of 7.2 million cy of
contaminated sediment would
permanently reduce volume of
contaminants in Area of Focus.
Thermal treatment of 1.7 million
cy would irreversibly destroy
contaminants.
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Short Term Effectiveness
Implementability
Cost
DMM
Scenario A(4)
DMM
Scenario B(5)
Some decreases in
existing risks are achieved
from natural recovery
processes, but acceptable
levels of risk are not
achieved within a
reasonable time frame (30
years).
Implementable.
Requires no action.
Gradual increase in
flooding impact.
Change in authorized
depth required.
Not applicable
Not applicable
Greatest amount of
removal results in greatest
potential for disturbance
and environmental
impact.
Implementable.
Slight decrease in
flooding. No change
in authorized depth
required.
$2.0 Billion
$2.3 Billion
Lowest amount of
removal results in lowest
potential for disturbance
and environmental
impact.
Considerable increase
in flooding. Change
in authorized depth
required.
$0.9 Billion
$1.1 Billion
Relatively moderate
amount of removal results
in moderate potential for
disturbance and
environmental impact.
Implementable.
Slight decrease in
flooding. No change
in authorized depth
required.
$1.5 Billion
$1.9 Billion
Relatively lower amount
of removal results in
relatively lower potential
for disturbance and
environmental impact.
Considerable increase
in flooding. Change
in authorized depth
required.
$1.3 Billion
$1.6 Billion
Relatively moderate
amount of removal results
in moderate potential for
disturbance and
environmental impact.
Implementable.
Slight decrease in
flooding. Change in
authorized depth
required.
$1.4 Billion
$1.8 Billion
Relatively moderate
amount of removal results
in moderate potential for
disturbance and
environmental impact.
Implementable.
Slight decrease in
flooding. Change in
authorized depth
required.
$1.5 Billion
$1.8 Billion
June 2007
Table C: Summary of Quantitative Estimates for Six Remedial Alternatives
Alternatives
•
Navigation Usage
Navigation channel depths(1)
Flooding(2)
(additional
flooding)
Dredging Volume
(millions of cubic
yards)
Construction
Duration (years)
Human Health
Risk Assessment(3)
Fish Consumption
Ecological Risk
Assessment(3)
Heron (5)
(4)
No Action
Similar to Current Use Alternative 4; limits
feasibility of future channel maintenance.
Gradual increase
with time
(not estimated)
Alternative 1: Removal of Fine-Grained Sediment from Area
of Focus
Authorized channel dimensions accommodated
(see Alternative 3 below).
Alternative 2: Engineered Capping of Area of Focus
Alternative 3: Engineered Capping of Area of Focus
Following Reconstruction of Federally Authorized
Navigation Channel
Alternative 4: Engineered Capping of Area of Focus
Following Construction of Navigation Channel to
Accommodate Current Usage
Alternative 5: Engineered Capping of Area of Focus
Following Construction of Navigation Channel for Future
Use
Alternative 6: Engineered Capping of Area of Focus
Following Construction of Navigation Channel for Future
Use and Removal of Fine Grained Sediment from Primary
Inventory Zone and Primary Erosional Zone
DMM
Scenario B(7)
Not applicable
Not applicable
Not applicable
Decrease
(not estimated)
11.0
12
$2.0 Billion
$2.3 Billion
Navigation significantly reduced.
Considerable
Increase
(93 acres)
1.1
6
$0.9 Billion
$1.1 Billion
Authorized channel dimensions accommodated.
• 30’ from RM0 to RM2.5
• 20’ from RM2.5 to RM4.6
• 16’ from RM4.6 to RM8.1
• 10’ above RM8.1
Decrease
(not estimated)
7.0
8
$1.5 Billion
$1.9 Billion
Anticipated future navigation usage accommodated.
• 30’ from RM0 to RM1.2
• 16’ from RM1.2 to RM3.6
• 10’ above RM3.6
Considerable
Increase
(24 acres)
5 E-04
(95% reduction
compared to
current)
5
DMM
Scenario A(6)
0
Current navigation usage accommodated.
• 30’ from RM0 to RM1.2
• 16’ from RM1.2 to RM2.5
• Navigation above RM2.5 significantly reduced
4 E-03
Total Present Worth Cost
2
4.4
6
$1.3 Billion
$1.6 Billion
Decrease
(-17 acres)
6.1
7
$1.4 Billion
$1.8 Billion
Decrease
(not estimated)
7.0
8
$1.5 Billion
$1.8 Billion
Notes:
(1) Navigation channel depths are provided in feet below mean low water.
(2) Flood estimates are provided for the 100-year return interval river flow event.
(3) Risk reductions presented are for 30 year timeframe. Alternatives 1 through 6 rely on monitored natural recovery with institutional controls in place to achieve 1E-04 and HI=1 in subsequent years. In addition, separate source control
actions above Dundee Dam, when implemented, will accelerate the time frame to reach 1E04 and HI=1.
(4) A human health risk assessment was also conducted for the scenario of crab consumption. More information is presented in Appendix C: Risk Assessment.
(5) An ecological risk assessment was also conducted for other species. More information is presented in Appendix C: Risk Assessment.
(6) Dredged Material Management Scenario A: Nearshore Confined Disposal
(7) Dredged Material Management B: Nearshore Confined Disposal, Storage, Thermal Treatment, and Beneficial Use
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Legend
Operation and
Maintenance Costs
3000
Dredged Material
Management Costs
2500
Capital Costs
Cost [$M]
2000
Notes
DMM Scenario A:
Nearshore Confined
Disposal
1500
DMM Scenario B:
Nearshore Confined
Disposal, Storage, Thermal
Treatment, and Beneficial
Use
1000
500
Acronyms
0
DMM
Scenario A
DMM
Scenario B
Alternative 1 : Dredging
DMM
Scenario A
DMM
Scenario B
Alternative 2 : Capping
DMM
Scenario A
DMM
Scenario B
Alternative 3: NCC Authorized Channel
DMM
Scenario A
DMM
Scenario B
Alternative 4: NCC Current Use Channel
DMM
Scenario A
DMM
Scenario B
Alternative 5: NCC Future Use Channel
DMM
Scenario A
DMM
Scenario B
Alternative 6: NCC Future Use Channel +
Dredging Primary
Erosional and Primary
Inventory Zones
DMM = Dredged Material
Management
NCC = Navigationally
Constrained Capping
Draft Contractor Document:
Subject to Continuing Agency
Review
Remedial Alternatives Cost Comparison
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Figure A
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Draft
Draft Contractor Document: Subject to Continuing Agency Review
LOWER PASSAIC RIVER RESTORATION PROJECT
SOURCE CONTROL EARLY ACTION FOCUSED FEASIBILITY STUDY
TABLE OF CONTENTS
EXECUTIVE SUMMARY ................................................................................................. i
1.0
Introduction.......................................................................................................... 1-1
1.1
Purpose and Organization ................................................................................ 1-1
1.1.1
Purpose..................................................................................................... 1-1
1.1.2
Organization of the Focused Feasibility Study........................................ 1-2
1.2
Definition ......................................................................................................... 1-3
1.3
Background Information.................................................................................. 1-6
1.3.1
Study Background.................................................................................... 1-6
1.3.2
CSM of the Lower Passaic River............................................................. 1-7
2.0
Development of Remedial Action Objectives and Selection of Target Areas..... 2-1
2.1
Remedial Action Objectives ............................................................................ 2-1
2.1.1
Overall Study Goals................................................................................. 2-1
2.1.2
Remedial Action Objectives for the Source Control Early Action.......... 2-2
2.2
Overview of ARARs........................................................................................ 2-3
2.2.1
Definition of ARARs ............................................................................... 2-3
2.2.2
“To Be Considered” Information............................................................. 2-4
2.2.3
Types of ARARs...................................................................................... 2-5
2.2.4
Waiver of ARARs.................................................................................... 2-5
2.3
Development of ARARs .................................................................................. 2-6
2.3.1
Chemical-Specific ARARs and TBCs ..................................................... 2-6
2.3.2
Location-Specific ARARs and TBCs ...................................................... 2-7
2.3.3
Action-Specific ARARs and TBCs ......................................................... 2-8
2.4
Development of Preliminary Remediation Goals .......................................... 2-10
2.4.1
Human Health Preliminary Remediation Goals .................................... 2-11
2.4.2
Ecological Preliminary Remediation Goals........................................... 2-13
2.4.3
Identification of Background Concentrations........................................ 2-15
2.4.4
PRG Selection........................................................................................ 2-17
2.5
Identification of Potential Target Areas for Remediation.............................. 2-18
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2.5.1
Target Area Identification Analyses ...................................................... 2-19
2.5.2
Estimation of Future Concentration in Surface Sediments.................... 2-21
2.6
Risk Reduction Resulting From Remediation of Identified Target Areas..... 2-23
2.6.1
Human Health Risk Assessment Summary ........................................... 2-23
2.6.2
Ecological Risk Assessment Summary.................................................. 2-26
2.6.3
Comparison of Reduction of COPC and COPEC Concentrations......... 2-28
2.7
3.0
Selection of Target Area for Remediation ..................................................... 2-31
Identification and Screening of General Response Actions, Remedial Technology
Classes, and Process Options........................................................................................... 3-1
3.1
Identification of General Response Actions .................................................... 3-2
3.1.1
No Action................................................................................................. 3-2
3.1.2
Institutional Controls ............................................................................... 3-2
3.1.3
Monitored Natural Recovery ................................................................... 3-3
3.1.4
Containment............................................................................................. 3-3
3.1.5
In Situ Treatment ..................................................................................... 3-3
3.1.6
Sediment Removal ................................................................................... 3-3
3.1.7
Ex Situ Treatment .................................................................................... 3-4
3.1.8
Beneficial Use of Dredged Sediments ..................................................... 3-4
3.1.9
Disposal of Dredged Sediments............................................................... 3-4
3.2
Sources and Methods for the Identification of Potentially Applicable
Technologies ................................................................................................................ 3-4
3.3
Technology Class Identification and Screening .............................................. 3-5
3.3.1
General Response Action: No Action...................................................... 3-7
3.3.2
General Response Action: Institutional Controls .................................... 3-7
3.3.3
General Response Action: Monitored Natural Recovery ........................ 3-8
3.3.4
General Response Action: Containment.................................................. 3-8
3.3.5
General Response Action: In Situ Treatment ........................................ 3-10
3.3.6
General Response Action: Sediment Removal ...................................... 3-13
3.3.7
General Response Action: Ex Situ Treatment ....................................... 3-14
3.3.8
General Response Action: Beneficial Use of Dredged Sediments ........ 3-18
3.3.9
General Response Action: Disposal of Dredged Sediments.................. 3-19
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3.4
Ancillary Technologies.................................................................................. 3-21
3.4.1
Sediment Dispersion Controls ............................................................... 3-22
3.4.2
Dewatering............................................................................................. 3-23
3.4.3
Wastewater Treatment ........................................................................... 3-24
3.4.4
Transportation ........................................................................................ 3-25
3.4.5
Restoration ............................................................................................. 3-26
3.5
4.0
Identification of Retained Process Options.................................................... 3-27
Development of Remedial Action Alternatives................................................... 4-1
4.1
Alternative Development Criteria.................................................................... 4-1
4.1.1
ARARs..................................................................................................... 4-1
4.1.2
Statutory Preferences ............................................................................... 4-1
4.1.3
Navigation Requirements......................................................................... 4-2
4.2
Selection of Representative Process Options................................................... 4-5
4.3
Development of Remedial Alternatives........................................................... 4-9
4.3.1
Bases for Concept Development............................................................ 4-10
4.3.2
Remedial Alternative Descriptions ........................................................ 4-26
5.0
Detailed Analysis of Remedial Alternatives........................................................ 5-1
5.1
Evaluation Process and Evaluation Criteria..................................................... 5-1
5.1.1
Threshold Criteria .................................................................................... 5-2
5.1.2
Primary Balancing Criteria ...................................................................... 5-4
5.1.3
Modifying Criteria ................................................................................. 5-15
5.2
Analysis of Alternatives................................................................................. 5-16
5.2.1
Overall Protection of Human Health and the Environment................... 5-16
5.2.2
Compliance with ARARs ...................................................................... 5-17
5.2.3
Long Term Effectiveness and Permanence............................................ 5-17
5.2.4
Reduction of Toxicity, Mobility, and Volume through Treatment........ 5-20
5.2.5
Short Term Effectiveness....................................................................... 5-22
5.2.6
Implementability .................................................................................... 5-24
5.2.7
Cost ........................................................................................................ 5-26
6.0
Acronyms............................................................................................................. 6-1
7.0
References............................................................................................................ 7-1
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LOWER PASSAIC RIVER RESTORATION PROJECT
SOURCE CONTROL EARLY ACTION FOCUSED FEASIBILITY STUDY
LIST OF TABLES
Tables identified as “(attached)” are in the “Tables” section following the document text.
Other tables are contained within the document text.
Table 2-1:
ARARs and TBCs (attached)
Table 2-2:
Summary of the PRGs Developed for Fish/Crab Tissue
Table 2-3:
Summary of the PRGs Developed for Sediment
Table 2-4:
Summary of Sediment PRGs for Ecological Receptors
Table 2-5:
Summary of Fish Tissue PRGs for Ecological Receptors
Table 2-6:
Background COPEC and COPC Concentrations
Table 2-7:
PRG Selection (attached)
Table 2-8:
Prediction Process for Concentrations in Surface Sediment for the Risk
Assessment
Table 2-9:
Forecasted COPC/COPEC Concentrations in Surface Sediments for Year
2048 (attached)
Table 2-10:
Forecasted Concentrations in Surface Sediment Compared to Background
Concentrations from the Upper Passaic River
Table 2-11:
Summary of Baseline and Future Cancer Risk and Non-cancer Health
Hazards and the Relative Reductions in Risk/Hazard after 30 Years
Table 2-12:
Summary of Ecological Hazards Associated with Current Conditions and
Various Remedial Scenarios
Table 2-13:
Time Difference between MNR Scenario and Area of Focus Scenario
Table 3-1:
General Response Actions (attached)
Table 3-2:
Dewatering Methods
Table 4-1:
Preliminary Dredging Requirements for Navigationally Constrained
Capping Alternatives (attached)
Table 4-2:
Total Areas (acres) Flooded Under Different Remedial Scenarios
Table 4-3:
Summary of Estimates for Remedial Alternatives (attached)
Table 5-1:
Detailed Analysis of Alternatives (attached)
Table 5-2:
ARARs for Remediation Elements (attached)
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SOURCE CONTROL EARLY ACTION FOCUSED FEASIBILITY STUDY
LIST OF FIGURES
Figure 1-1:
Study Area Location Map
Figure 1-2:
Comparison of River Mile Systems
Figure 1-3:
Variation of Lower Passaic River Cross-Sectional Area with River Mile
Figure 1-4:
Percent Spatial Coverage of Net Erosional, Net Depositional, and
Bathymetrically Neutral Areas
Figure 1-5:
Schematic of Nature and Extent of Contamination in Sediment Beds
Figure 1-6:
Weighted Curve Sediment Inventory vs. River Mile
Figure 2-1:
Potential Target Areas
Figure 2-2:
Identification of Primary Erosional Zone
Figure 2-3:
Identification of Primary Inventory Zone
Figure 4-1:
Conceptual Design: Alternative 1
Figure 4-2:
Conceptual Design: Alternative 2
Figure 4-3:
Conceptual Design: Alternative 3
Figure 4-4:
Conceptual Design: Alternative 4
Figure 4-5:
Conceptual Design: Alternative 5
Figure 4-6:
Conceptual Design: Alternative 6
Figure 4-7:
Schematic of Cap Concepts
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SOURCE CONTROL EARLY ACTION FOCUSED FEASIBILITY STUDY
LIST OF APPENDICES
Appendix A: Conceptual Site Model
Appendix B: Sediment TBCs and Development of Preliminary Remediation Goals
Appendix C: Risk Assessment
Appendix D: Empirical Mass Balance Model
Appendix E: Engineering Memoranda
Appendix F: Navigation Studies
Appendix G: Cap Erosion and Flood Modeling
Appendix H: Dredged Material Management Assessments
Appendix I:
Dredging Volume Estimates
Appendix J:
Cost Estimates
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Mention of trade names or commercial products in this Focused Feasibility Study is for
purposes of evaluating remedial alternatives only, and does not constitute endorsement of
any product or manufacturer by the United States Environmental Protection Agency.
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1.0
1.1
PURPOSE AND ORGANIZATION
1.1.1
Purpose
INTRODUCTION
The Lower Passaic River Restoration Project (herein referred to as the Study) is a
comprehensive study of the 17-mile tidal portion of the Passaic River and its watershed
(Figure 1-1). During the course of the Study, the sediments of the lower eight miles of
the river were identified as a major source of contamination to the 17-mile Study Area.
Therefore, a Focused Feasibility Study (FFS) was undertaken to evaluate a range of
remedial alternatives that might be implemented as an early action to control that source.
This Source Control Early Action, if undertaken, would address some or all of the
contaminated sediments in the lower eight miles of the Passaic River, in order to reduce
risks to human health and the environment. The Source Control Early Action, which
would be a final action for the sediments in the lower eight miles, is intended to take
place in the near term, while the comprehensive 17-mile study is on-going.
The Area of Focus for this FFS is the predominantly fine-grained, contaminated sediment
present in the Brackish and Transitional Sections 1 of the Lower Passaic River.
Geomorphological data suggest fine-grained sediments exist in a contiguous stretch up to
approximately river mile (RM) 8. Therefore, remedial alternatives have been developed
to consider remedial action in the lower 8 miles. While the preponderance of available
contaminant data represents the area between RM1 and RM7, the Conceptual Site Model
(CSM) (Appendix A) suggests that RM0 to RM1 and RM7 to RM8 will behave similarly
to the area between RM1 to RM7.
1
As described in the Conceptual Site Model (Appendix A), the Lower Passaic River may be divided into
three sections: a Freshwater section dominated by freshwater flow entering over Dundee Dam, a Brackish
section dominated by saline waters from Newark Bay, and a Transitional section where the two mix.
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Historical data and data gathered during remedial investigation (RI) activities to date
were used to develop the CSM, identify potential target areas for remediation, and
characterize current risk. Potentially applicable technologies have been identified,
evaluated for their suitability for use at the site, and assembled into remedial alternatives.
A comparative analysis of these remedial alternatives, consistent with the United States
Environmental Protection Agency (USEPA) guidance documents for preparing feasibility
studies (USEPA, 1988) and for addressing contaminated sediment (USEPA, 2005), is
also presented.
1.1.2 Organization of the Focused Feasibility Study
The FFS is organized into the following sections:
Section 1.0, INTRODUCTION: This section provides introductory and background
material, as well as a CSM that summarizes the nature and extent of contamination in the
Study Area, as well as the fate and transport of suspended solids and contaminants in the
Lower Passaic River and Newark Bay. 2 This section also includes definitions for terms
used in this document.
Section 2.0, DEVELOPMENT OF REMEDIAL ACTION OBJECTIVES AND
SELECTION OF TARGET AREAS: This section presents the potential applicable or
relevant and appropriate requirements (ARARs), which are the Federal and State
environmental regulations that may pertain to a remedial action, as well as other to-beconsidered (TBC) criteria, which are non-promulgated guidance, advisories, and
proposed standards issued by Federal or State agencies. This section also presents the
current knowledge of contaminant bioaccumulation and risks to human health and the
environment posed by contaminants in the Area of Focus, as well as a prediction of future
surface concentrations generated using the Empirical Mass Balance Model (Appendix D),
which also refines conclusions presented in the CSM. The criteria for identifying areas
2
The CSM is presented in full in Appendix A and illustrates biotic, as well as physical and chemical,
processes; human health and ecological risk pathways and receptors are presented in the Risk Assessment
(Appendix C).
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of the river for potential remediation are presented, along with Remedial Action
Objectives (RAOs) and Preliminary Remediation Goals (PRGs).
Section 3.0, IDENTIFICATION AND SCREENING OF GENERAL RESPONSE
ACTIONS, REMEDIAL TECHNOLOGY CLASSES, AND PROCESS OPTIONS:
This section presents a review of general response actions, remedial technology classes,
and process options that may be used to achieve the RAOs identified in Section 2.0
“Development of Remedial Action Objectives and Selection of Target Areas.” The
process options are screened for applicability in developing remedial alternatives for the
Area of Focus.
Section 4.0, DEVELOPMENT OF REMEDIAL ACTION ALTERNATIVES: This
section presents the development and conceptual description of remedial alternatives. In
addition to the No Action alternative, six active remedial alternatives are presented for
remediating the lower 8 miles of the Passaic River.
Section 5.0, DETAILED ANALYSIS OF ALTERNATIVES: This section presents a
detailed description and analysis of features unique to each alternative, according to each
of the seven Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA) evaluation criteria required to be addressed in the FFS report. Also included
is a comparative analysis of the remedial alternatives.
Section 6.0, ACRONYMS: This section provides the definitions for the acronyms used
in this document.
Section 7.0, REFERENCES: This section provides a list of the references used in this
document.
1.2
DEFINITION
In order to aid the reader, the following definitions of terms frequently used in this
document are provided.
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•
Area of Focus: Contaminated sediments present in RM0 to RM8.3 [remedial
investigation and feasibility study (RI/FS) RM0 to RI/FS RM8]. (RM systems are
also defined in this section.)
•
Armor: Material (e.g., stone) placed over a cap to withstand erosive forces.
•
Authorized Channel: The navigation channel with limits as determined by the United
States Congress and entrusted to the United States Army Corps of Engineers
(USACE).
•
Backfill: Material placed to mitigate dredging residuals; unlike a cap, backfill is not
required to be maintained after placement.
•
Cap or Engineered Cap: Layer of material placed over contaminated sediment to
reduce migration of contamination from the underlying sediment.
•
Confined Disposal Facility (CDF): Basin designed to accept dredged material,
typically using berms, dikes, or walls to isolate dredged material from surroundings
and provide gravity dewatering; can be used in upland, nearshore, or off-shore
(island) configurations.
•
Contained Aquatic Disposal (CAD): Placement of dredged material into an excavated
or existing subaqueous depression, followed by placement of cover material.
•
Contaminant Inventory: The quantity of a particular contaminant in a given area or
river reach with units of mass.
•
Far Field: Area in an aquatic system in which a sediment plume due to a disturbance
(e.g., dredging) will be relatively well-mixed in the water column and the particles
will remain suspended indefinitely; empirically defined in this system as greater than
approximately 1000 feet (300 meters) from the point of disturbance.
•
Fine-Grained Sediment: Sediment that falls predominantly in the silt or clay category
as defined under the Unified Soil Classification System.
•
Head-of-Tide: Up-estuary limit of the influence of tidal forcing on water surface
elevation.
•
Hot Spot: Area of sediment contamination that can be distinguished from adjacent
sediments by a relatively sharply defined gradient in chemical concentration or mass
per unit area.
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•
Hot Zone: Extensive area of sediment contamination characterized by a large
inventory with chemical concentration or mass per unit area that declines only
gradually with distance from its centroid and has no well-defined boundary.
•
Mudflat: Area of fine-grained, consolidated sediment (at least 50 feet wide for
practical purposes) that is intermittently exposed and submerged by tidal fluctuation.
•
Navigational Channel (often shortened to “Channel”): Portion of a waterbody which
is defined to accommodate the passage of waterborne vessels.
•
Near Field: Area in an aquatic system within which a sediment plume due to a
disturbance (e.g., dredging) will not be reliably well-mixed in the water column and
many suspended particles will settle out; empirically defined in this system as less
than approximately 1000 feet (300 meters) from the point of disturbance.
•
Primary Erosional Zone: Area of the Lower Passaic River in which there exists a
greater amount of surface area that may erode as compared to other areas of the river.
•
Primary Inventory Zone: Area of the Lower Passaic River in which there exists a
relatively greater contaminant inventory as compared to other areas of the river.
•
River Mile System: Two systems exist for identifying locations by RM in the Lower
Passaic River. The system used in this document to identify locations in the river is
based on measurements made, using units of RM, along the centerline of the USACE
navigation channel, starting from the downriver terminus of the navigation channel.
However, Appendix A “Conceptual Site Model,” Appendix C “Risk Assessment,”
Appendix D “Empirical Mass Balance Model,” and other locations (e.g., figures)
where specifically noted, use a slightly (about 1/4 mile) different river mile system,
which is referred to in this document as the “RI/FS RM” system. The RI/FS RM
system uses measurements made in units of RM along a centerline that is equidistant
from each shore. Figure 1-2 displays both river mile systems. In instances in this
document when precision is required, the location will be provided using both
systems, first using the USACE navigation channel river mile designation as a
reference, and parenthetically using the RI/FS river mile designation as a reference.
In instances when approximate location is sufficient, the location will be provided
only using the USACE system, except in the appendices mentioned above, where the
RI/FS system will be used.
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•
Shoal: Area between the navigation channel and the shoreline.
•
Thalweg: Deepest portion of river cross-section, in which greatest water velocities
occur.
1.3
BACKGROUND INFORMATION
1.3.1
Study Background
The Study is an interagency effort to remediate and restore the complex ecosystem of the
Lower Passaic River, which is the 17-mile tidally-influenced portion of the river located
in northern New Jersey. The Study Area (118 square miles) is defined as the Lower
Passaic River and its basin, which comprises the tidally-influenced portion of the river
from the Dundee Dam (RM17) to Newark Bay (RM0), and the watershed of this river
portion downstream of the dam, including the Saddle River, Second River, and Third
River (Figure 1-1). The Lower Passaic River is an Operable Unit of the Diamond Alkali
Superfund Site in Newark, New Jersey.
The USEPA, USACE, and New Jersey Department of Transportation (NJDOT) have
partnered with the National Oceanic and Atmospheric Administration (NOAA), United
States Fish and Wildlife Service (USFWS), and New Jersey Department of
Environmental Protection (NJDEP) to bring together the authorities of the CERCLA and
the Water Resources Development Act (WRDA) to produce the comprehensive Study of
the Lower Passaic River. The Study is an integrated, joint effort among the partner
agencies to examine the ecosystem problems within the watershed and to identify
remediation and restoration options to address these problems. Natural resource injuries
are also being addressed in this comprehensive plan to the extent possible. The scope of
the Study is to gather data needed to make decisions on:
•
Remediating contamination in the river to reduce human health and ecological risks.
•
Improving the water quality of the river.
•
Improving and creating aquatic habitat.
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•
Improving human use.
•
Reducing contaminant loading in the Lower Passaic River and the New York-New
Jersey Harbor Estuary.
•
Reducing future natural resource injuries.
This FFS was undertaken by the partner agencies to evaluate whether an early action
could be implemented to control the sediments in the lower eight miles of the river,
because they were identified as a major source of contamination to the Study Area. The
FFS is being developed while the comprehensive Study is on-going.
1.3.2
CSM of the Lower Passaic River
A CSM 3 for the Study was initially presented in the August 2005 version of the Work
Plan (Malcolm Pirnie, Inc., 2005b). This CSM has been updated as part of this FFS. A
brief summary of conclusions discussed in Appendix A “Conceptual Site Model” is
presented below.
The Lower Passaic River was one of the major centers of the American industrial
revolution, with early manufacturing, particularly cotton mills, developing in the area
around the Great Falls in Paterson, New Jersey. In subsequent years, a multitude of
industrial operations developed along the banks of the Passaic River, as the cities of
Newark and Paterson grew. These industrial operations included manufactured gas
plants, paper manufacturing and recycling facilities, chemical manufacturing facilities,
and others that used the river for wastewater disposal. Moreover, the Lower Passaic
River has been used as a major means of conveyance for municipal discharges from the
middle of the nineteenth century to the present time. Ultimately, many contaminants
were discharged to the Lower Passaic River, including 2,3,7,8-tetrachlorodibenzo-pdioxin (2,3,7,8-TCDD), polycyclic aromatic hydrocarbons (PAH), polychlorinated
biphenyls (PCB), pesticides such as DDT, and heavy metals such as mercury and lead.
3
A CSM expresses a site-specific contamination problem through a series of diagrams, figures, and
narrative consistent with USEPA Office of Solid Waste and Emergency Response (OSWER) remedial
investigation and feasibility study guidance (USEPA, 1988).
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The Lower Passaic River is a partially stratified estuary where the degree of stratification
and the location of the salt front at any point in time reflect a dynamic balance between
the freshwater flow and the tidal exchange with Newark Bay. Tidal displacement in the
Lower Passaic River is quite large, with the salt front moving several miles during each
tidal cycle.
An important component of the region’s development and urbanization was the
deepening of the river to permit commercial vessels to travel to the city of Newark and
farther upriver. Several large dredging projects were undertaken at the beginning of the
twentieth century to create a navigation channel to approximately RM15. Since the
1940s, there has been little maintenance dredging above RM2. Consequently, extensive
fine grained sediment deposits exist in the channel, particularly between RM2.5 and
RM8. The coincidence of contaminant discharges to the river and a significant
suspended sediment load created an ideal situation for accumulating contaminated
sediments. As a result, the river accumulated substantial sediment beds, measuring up to
25 feet thick in some areas. These thick sediment deposits remain, primarily below RM8
where the relatively wider river channel provided favorable conditions for rapid sediment
accumulation. Relatively little accumulation has occurred upstream of RM8 because of
the narrower channel conditions. The change in river geometry is illustrated in Figure 13, which shows the relationship between location and the river’s cross sectional area.
Despite the prevalence of thick sediment deposits below RM8, the sediments in this
region are not all stable, and erosional areas have been identified throughout the lower 8
miles of the river. These erosional areas are believed to be responsible for on-going
releases of contaminants from the river bed. This is shown in Figure 1-4, which plots the
percentage of depositional and erosional area as a function of river mile. A detailed
examination of sediment deposition rates between RM1 and RM7 indicates a high degree
of spatial heterogeneity, with local rates varying from about 6 inches/year of erosion to
about 8 inches/year of deposition. Historical deposition rates were probably higher than
current rates because of the more extensive salt front intrusion and deeper channel depths
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immediately after the initial channel dredging, which would have enhanced settling of
suspended sediment. A comparison of current and historical mass balances of solids
coming into the Lower Passaic River shows that the relative importance of the solids load
coming from the head-of-tide has increased over the years, compared to that coming from
Newark Bay. The current head-of-tide solids load to the Lower Passaic River is greater
than the annual average rate of accumulation in the river; however, the historical rates of
sediment accumulation in the Lower Passaic River were probably too large to be
sustained solely by the Passaic’s head-of-tide solids loads, suggesting that solids transport
from Newark Bay may have supplied the additional solids.
The CSM demonstrates that toxic constituent concentrations in the water column and
biota of the Lower Passaic River are largely driven by contaminants contained within the
sediments, particularly for 2,3,7,8-TCDD. While on-going external inputs may exist, the
concentrations within the sediments are responsible for much of the contamination within
the water column. In fact, the legacy of sediment contamination probably extends back at
least to the mid-nineteenth century. The oldest contaminants found in the sediments are
PAH compounds, cadmium, mercury, and lead, which probably pre-date the turn of the
twentieth century. Following these contaminants are, in order of chronological
appearance in the river, DDT; 2,3,7,8-TCDD; and PCB. Other contaminants, such as
arsenic, chromium, and copper are also present in the sediment record. The vertical
extent of these contaminants is illustrated schematically in Figure 1-5. The available
evidence indicates that several of these compounds (i.e., PAH, PCB, mercury, and lead)
at least partially originated above the head-of-tide and Dundee Dam. Others, like 2,3,7,8TCDD and DDT, are nearly exclusively the result of discharges to the Lower Passaic
River.
Ratio analysis of several organic constituents has permitted the “fingerprinting” of the
source material. Using these techniques, 2,3,7,8-TCDD contamination is shown to be
derived almost exclusively from resuspension of legacy sediments (derived from
historical industrial discharges) in the Lower Passaic River. PAH patterns indicate that
the majority of PAH contamination in the sediments is derived from combustion-related
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processes, specifically coal tar residue (a by-product of manufactured gas plants) and
urban background combustion, nearly all of which currently enters the Lower Passaic at
Dundee Dam. Of these, coal tar wastes are historically the dominant source to the Lower
Passaic River. For PCB, there are two main sources to the Lower Passaic River of
roughly equal magnitude. The resuspension of legacy sediments contributes a mixture of
low molecular weight PCB congeners while the flow from the Upper Passaic River (over
the Dundee Dam) contributes a higher molecular weight PCB mixture.
One important observation from the extent of chemical contamination in the Lower
Passaic River is the extent of tidal mixing throughout the river. Recently deposited
sediments throughout the Lower Passaic River have very similar, and elevated,
concentrations of contaminants, indicating that sediments are well homogenized prior to
deposition. Thus, the presence or absence of an interval of high concentration within the
sediments at a given location is a function of the depositional history at that location and
is generally not controlled by proximity to source. As a result, thick sequences of
contaminated sediments will tend to have similar inventories of contaminants regardless
of their location in the river.
The volume of contaminated fine-grained sediment is estimated at between 5 million and
8 million cubic yards for RM1 to RM7, with an average depth of contamination ranging
from 7 to 13 feet. Extrapolating the contaminant sediment volume estimate into RM0 to
RM1 and RM7 to RM8 increases the contaminated sediment volume estimate by
approximately one-third, to between 6 million and 10 million cubic yards.
Contaminant inventories are not evenly distributed and vary along the length of the
Lower Passaic River, with maximum values occurring near the areas encompassing RM1
to RM2, RM3 to RM4, and RM6 to RM7 (Figure 1-6). The coring data that form the
basis for these inventories show a high degree of local spatial heterogeneity, indicating
that localized areas of relatively higher concentrations typically described as “hot spots”
may not exist. Instead, “hot zones” of the river seem to exist on the scale of a mile or
more, nearly bank to bank (i.e., the width of the navigation channel plus historical berth
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areas) in lateral extent. This conclusion does not, however, diminish the significance of
potential historic or current point sources as the origin of contaminant inventory in the
Lower Passaic River. Estuarine mechanisms are believed to quickly render contaminant
concentration gradients indistinct on the scales examined here. It is possible that
environmental sampling on a finer scale (on the order of less than a quarter mile) would
identify localized gradients near prominent historical or current source areas.
The Lower Passaic River is a major source of contaminants to Newark Bay. Solids
transport to Newark Bay delivers the contaminants found in surficial sediments,
particularly 2,3,7,8-TCDD. It is estimated that the Lower Passaic River contributes
approximately 10 percent of the total amount of solids accumulating in Newark Bay, and
more than 80 percent of the 2,3,7,8-TCDD accumulating in the Bay. No other single
source delivers more than 10 percent of the total 2,3,7,8-TCDD load. A similar mass
balance analysis for mercury shows that, despite the high mercury concentrations in the
sediments of the Lower Passaic River, the Lower Passaic River sediments are only
responsible for approximately 20 percent of the total mercury load to Newark Bay
(although 20 percent is not an insignificant contribution). Moreover, the known sources
of mercury to Newark Bay cannot account for the annual accumulation of mercury in the
sediment beds of the Bay. The “missing” mercury source represents the largest single
“source” of mercury to Newark Bay, constituting approximately 35 percent of the annual
mercury load.
In summary, although the Lower Passaic River is a partially stratified estuary, the tidal
excursion is sufficiently energetic that the water column remains well-mixed with respect
to suspended solids. Depositional rates in the Lower Passaic River are high due to
historical dredging and subsequent re-filling due to reduced maintenance, and the
combination of relatively well-mixed suspended matter and high deposition rates has
yielded thick sequences of contaminated sediments. Local variations in sediment
contaminant inventory are primarily attributed to variations in depositional rates, and not
proximity to local sources; however, the resolution of available data sets is not sufficient
to eliminate the possibility of very localized areas of high contaminant concentrations in
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the immediate vicinity of point sources. Surface concentrations in the Lower Passaic
River are relatively homogeneous over long distances, with the range typically less than a
factor of 3 along 12 miles or more of the river. Surface concentrations of many
contaminants (e.g., 2,3,7,8-TCDD) are maintained at high levels by resuspension of
older, more contaminated sediments. Conversely, the concentrations of several important
chemicals (e.g., PAH) are driven by head-of-tide loads. Concentrations of some
contaminants, such as PCB, are maintained by both head-of-tide influences and
resuspension of legacy sediments.
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2.0
DEVELOPMENT OF REMEDIAL ACTION OBJECTIVES
AND SELECTION OF TARGET AREAS
This section of the FFS introduces the requirements that must be met by any remedial
action, the objectives that remedial actions are designed to achieve, and the risk-based
selection of a target area (or areas) for remediation. CERCLA requires the development
of “...methods and criteria for determining the appropriate extent of removal, remedy, and
other measures...” for responding to releases of hazardous pollutants and contaminants
[CERCLA Section 105(a)(3)]. For the FFS, it was necessary to develop PRGs for
sediment to allow a rigorous evaluation of the remedial alternatives for the Lower Passaic
River. Because there are no chemical-specific ARARs pertaining to sediments (refer to
Section 2.3 “Development of ARARs”), the PRGs considered consist of risk-based
concentrations (RBCs) for fish tissue and sediment contaminants, as well as background
sediment contaminant concentrations. This section describes the regulatory framework in
which remediation goals were derived, the PRG development process, and the method
used to identify background contaminant concentration to the estuary.
2.1
REMEDIAL ACTION OBJECTIVES
2.1.1
Overall Study Goals
Study goals have been developed by the partner agencies to establish the direction for the
overall Study, which incorporates the CERCLA RI/FS to which this FFS pertains. These
overall study goals are the basis to evaluate:
•
Remediation of contaminated sediments.
•
Improvement of water quality.
•
Improvement and creation of aquatic habitat.
•
Enhancement of human use.
•
Reduction of contaminant loading in the Lower Passaic River and to the New YorkNew Jersey Harbor Estuary.
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As an FFS for a Source Control Early Action, this effort is intended to address the first
goal (i.e., remediation of contaminated sediments) to the extent practicable, while
contributing to achievement of the remaining goals prior to implementation of an overall
remedy.
2.1.2 Remedial Action Objectives for the Source Control Early Action
RAOs provide a general description of what the cleanup is expected to accomplish and
help focus the development of remedial alternatives in the FFS. RAOs specify the
contaminants and media of concern, exposure routes and potential receptors, and an
acceptable concentration limit or range for each contaminant for each of the various
media, exposure routes, and receptors. RAOs are developed to set targets for achieving
PRGs (ARARs and RBCs that are protective of human health and the environment) early
in the remedial alternative development process. The RAOs should be as specific as
possible, without unduly limiting the range of alternatives that can be developed. RAOs
for the Lower Passaic River Source Control Early Action are as follows:
•
Reduce cancer risks and non-cancer health hazards for people eating fish and shellfish
from the Lower Passaic River by reducing the concentration of contaminants of
potential concern (COPCs) in fish and shellfish.
•
Reduce the risks to ecological receptors by reducing the concentration of
contaminants of potential ecological concern (COPECs) in fish and shellfish.
•
Reduce the inventory (mass) of COPCs and COPECs in sediments that is or may
become bioavailable.
•
Remediate the most significant mass of contaminated sediments that may be mobile
(e.g., erosional or unstable sediments) to prevent it from acting as a source of
contaminants to the Lower Passaic River or to Newark Bay and the New York-New
Jersey Harbor Estuary.
It is implicit in the nature of an early action that potential actions should be suitable for
implementation within a reasonable time period, consistent with the USEPA guidance on
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accelerated Superfund cleanups, Introduction to Superfund Accelerated Cleanup Model
(USEPA, 1998b).
2.2
OVERVIEW OF ARARS
Section 121(d)(2) of CERCLA, as amended by the 1986 Superfund Amendments and
Reauthorization Act (SARA), requires that on-site remedial actions comply with state and
federal ARARs upon completion of the remedial action. Alternatively, certain
requirements may be specifically waived by the Regional Administrator, if justified. The
revised National Oil and Hazardous Substances Pollution Contingency Plan, otherwise
known as the National Contingency Plan (NCP), requires compliance with ARARs
during remedial actions as well as at completion.
The potential ARARs for the Study in each of the three categories [chemical-specific,
location-specific, and action-specific (refer to Section 2.2.3 “Types of ARARs”)] along
with other TBC criteria, are summarized in Table 2-1 and discussed below. It should be
noted that ARARs are potentially applicable in this FFS and become final upon issuance
of the record of decision (ROD). The ARARs included here have been identified based
on the alternatives considered and, depending upon the alternative ultimately selected,
may not be included in a final decision document.
2.2.1
Definition of ARARs
ARARs consist of two sets of requirements: those that are applicable and those that are
relevant and appropriate. Applicable requirements are those substantive standards,
requirements, criteria, or limitations promulgated under federal environmental or state
environmental or facility siting laws that specifically address a hazardous substance,
pollutant, contaminant, remedial action, location, or other circumstance at a CERCLA
site. Relevant and appropriate requirements are those substantive standards,
requirements, criteria, or limitations promulgated under federal environmental or state
environmental or facility siting laws that, while not “applicable” to a hazardous
substance, pollutant, contaminant, remedial action, location, or other circumstance found
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at a site, address problems or situations similar to those encountered at the site so as to be
well-suited for use at the site.
On-site actions must attain those ARARs identified at the time of the ROD signature or
provide grounds for invoking a waiver [CERCLA Section 121(d); 40 Code of Federal
Regulations (CFR) Sections 300.430(f)(ii)IB) and 300.435(b)(2)]. The NCP defines
ARARs as substantive requirements, criteria or limitations. In contrast, procedural
requirements such as permit applications, reporting, record keeping and consultation with
administrative bodies are not ARARs. CERCLA specifies that no federal, state or local
permits are required for on-site response actions [CERCLA Section 121(e)]. Although
consultation with the state and federal offices responsible for issuing the permits is not
required, it is recommended for compliance with the substantive requirements. Permits
must be obtained for all response activities conducted off-site. Off-site actions must
comply with both the substantive and administrative parts of those requirements.
2.2.2
“To Be Considered” Information
Many federal and state environmental and public health agencies develop criteria,
advisories, guidance, and proposed standards that are not legally enforceable, but contain
information that would be helpful in carrying out, or in determining the level of
protectiveness of, selected remedies. TBC materials are meant to complement the use of
ARARs, not compete with or replace them. Because TBCs are not ARARs, their
identification and use are not mandatory.
Where no ARARs exist to address a particular situation, the TBCs may be used to set
cleanup targets (in conjunction with a baseline risk assessment). Many ARARs have
broad performance criteria but do not provide specific instructions for implementation.
Often, these instructions are contained in supplemental program guidance that may be
considered a TBC.
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2.2.3
Types of ARARs
Any substantive environmental requirement has the potential to be an ARAR. A
substantive requirement typically specifies a level or standard of control, although it
could also provide performance criteria or location restrictions. To simplify the universe
of such requirements, USEPA divides ARARs into three categories to facilitate
identification:
•
Chemical-Specific ARARs: These are either health- or risk-based numerical values or
methodologies that establish the acceptable amount or concentration of a chemical
that may remain in or be discharged to the environment. Where more than one
requirement addressing a contaminant is determined to be an ARAR, the most
stringent requirement should be applied, unless it is waived by the Regional
Administrator.
•
Location-Specific ARARs: These are restrictions of certain activities based on the
concentration of hazardous substances solely because of geographical or land use
concerns. Requirements addressing wetlands, historic places, floodplains, or
sensitive ecosystems and habitats are potential location-specific ARARs.
•
Action-Specific ARARs: These requirements set restrictions on the conduct of certain
activities or operation of certain technologies at a particular site, and are primarily
used to assess the feasibility of remedial technologies and alternatives. Regulations
that dictate the design, construction, and operating characteristics of incinerators,
other treatment units, or landfills are examples of action-specific ARARs.
2.2.4
Waiver of ARARs
CERCLA Section 121(d) provides that under certain circumstances an ARAR may be
waived. The six statutory waivers are as follows:
•
Interim Measure: occurs when the selected remedial action is only part of a total
remediation action that will attain ARARs when completed.
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•
Greater Risk to Health and the Environment: occurs when compliance with such
requirements will result in greater risk to human health and the environment than the
alternative options.
•
Technical Impracticability: occurs when compliance with such requirements is
technically impracticable from an engineering perspective.
•
Equivalent Standard of Performance: occurs when the selected remedial action will
provide a standard of performance equivalent to that required under the otherwise
applicable standard, requirement, criteria, or limitation through use of another method
or approach.
•
Inconsistent Application of State Requirements: occurs when a state requirement has
been inconsistently applied in similar circumstances at other remedial actions within
the state.
•
Fund-Balancing: occurs when, in the case of an action undertaken using Superfund
resources, the attainment of the ARAR would entail extremely high costs relative to
the added degree of reduction of risk afforded by the standard such that remedial
actions at other sites would be jeopardized.
2.3
DEVELOPMENT OF ARARS
Chemical-specific, location-specific, and action-specific ARARs and TBCs are
considered in the development and evaluation of remedial alternatives. When an
alternative is selected, it must be able to fulfill the requirements of all ARARs (or a
waiver must be justified). Table 2-1 (attached) provides a compilation of the ARARs and
TBCs identified for this FFS in consultation with the Partner Agencies. Also included in
Table 2-1 (attached) are brief descriptions of the cited requirements and summaries of the
actions, discharges, or processes resulting from the project activities to which the ARARs
and TBCs may apply.
2.3.1
Chemical-Specific ARARs and TBCs
Chemical-specific ARARs and TBCs define concentration limits or other chemical levels
for environmental media. Based on the RAOs for the Source Control Early Action FFS
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(Section 2.1.2 “Remedial Action Objectives for the Source Control Early Action”), only
requirements for sediment are considered here. There are no ARARs for sediments.
A broad universe of potential chemical-specific TBCs was initially identified from
criteria developed by other USEPA regions and a variety of other agencies (Appendix B
“Sediment TBCs and Development of Preliminary Remediation Goals”). Appendix B
Table B-1 presents a detailed inventory of these potential TBCs and their sources while
Table B-2 lists the associated contaminant screening values. As described in Section 2.4
“Development of Preliminary Remediation Goals,” PRGs were developed for the FFS.
These PRGs, while not ARARs, are concentration limits that have been developed
specifically for the Source Control Early Action based on site-specific RBCs. They are
thus considered to be more appropriate benchmarks for Early Action at the site than any
of the initially identified chemical-specific TBCs. As a result, all of the potential
chemical-specific TBCs were screened from consideration as viable criteria for the Early
Action.
2.3.2
Location-Specific ARARs and TBCs
The following location-specific ARARs were identified for the FFS:
•
Endangered Species Act, 16 United States Code (U.S.C.) §1536; 50 CFR §402
Subpart B: Broad protection is provided for species of fish, wildlife, and plants that
are listed as threatened or endangered in the United States or elsewhere.
•
Federal Consistency Determination, 15 CFR § 930.36: The Federal Consistency
Determination requires that federal agencies review their activities to determine
whether such activities will be undertaken in a manner consistent to the maximum
extent practicable with the enforceable policies of approved management programs.
•
Freshwater Wetlands Protection Act Rules, New Jersey Administrative Code
(N.J.A.C.) 7:7A-4.3: The Act regulates activities in freshwater wetlands, such as
excavation, drainage, discharge of material, driving pilings, placing obstructions to
flow, and destruction of plant life. The process for delineating a wetland and
determining the width of the transition zone is specified, and wetland mitigation
requirements are presented.
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•
National Historic Preservation Act (NHPA), 16 U.S.C. §470 et seq.; 36 CFR. Part
800: The NHPA requires consultation to identify historic properties potentially
affected by federal activities and to assess the effects and to seek ways to avoid,
minimize or mitigate any adverse impacts to those identified properties.
•
Soil Erosion and Sediment Control Act regulations, N.J.A.C. 7:13-3.3: These
regulations require controls for soil erosion and sediment prior to commencing any
land development projects.
•
Flood Hazard Control Act, N.J.S.A. 15:16A-50, et seq.: These regulations cover
stream encroachment activities and development in floodways and flood fringes.
Designs must prevent obstruction of flow or change in flow velocity in the case of a
flood. Evaluations are ongoing to determine the applicability of these regulations.
The following location-specific TBC was identified for the FFS:
•
NJDEP Soil Cleanup Criteria. [Contaminant Values for Residential Direct Contact
Soil Cleanup Criteria, Non- Residential Direct Contact Soil Cleanup Criteria, and
Impact to Ground Water Soil Cleanup Criteria; last revised May 12, 1999 (Note that
NJDEP proposed new Soil Cleanup Criteria in May 2007; the final rule is planned to
be promulgated after a public comment period ending July 27, 2007.)] The NJDEP
soil cleanup criteria will be utilized for determining the appropriateness of using
dredged sediments, or treated dredged sediments, for other beneficial land application
uses within the State of New Jersey.
2.3.3 Action-Specific ARARs and TBCs
The following action-specific ARARs are identified for the FFS:
•
Rivers and Harbors Act, 33 U.S.C. § 403: Activities that could impede navigation and
commerce are prohibited without authorization from the Secretary of the Army. Such
activities include obstruction or alteration of any navigable waterway, building of
bulkheads outside harbor lines and any excavation or fill in navigable waters. In
accordance with CERCLA Section 121(e)(1), no federal, state, or local permits are
required for remedial actions that are conducted entirely on site, although remedial
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actions must comply with the substantive requirements of the Rivers and Harbors
Act.
•
Section 404 of the Clean Water Act (CWA), 40 CFR Parts 321, 322, and 323: The
CWA includes requirements for the discharge of dredged or fill material into
navigable waters of the United States. The Act also regulates the construction of any
structure in navigable waters.
•
Resource Conservation and Recovery Act (RCRA), 40 CFR. § 261, 262, 264, 265,
and 268: Dredged material may be subject to RCRA regulations if it contains a listed
waste, or if it displays a hazardous waste characteristic based on the Toxicity
Characteristic Leaching Procedure (TCLP) test. RCRA regulations may potentially
be ARARs for the storage, treatment, and disposal of dredged material unless an
exemption applies. If dredged material is removed but replaced in water within the
Area of Contamination, which for this FFS includes the Lower Passaic River, Newark
Bay and areal extent of contamination, RCRA land disposal regulations (LDR) are
not triggered.
•
Toxic Substances Control Act (TSCA), 40 CFR. § 761: TSCA regulates PCBs from
manufacture to disposal. Remediation of sediments with PCB concentrations greater
than 50 milligrams per kilogram of sediment (mg/kg) or part per million (ppm) is
considered PCB waste remediation and is controlled under TSCA.
•
Hazardous Materials Transportation Act, 49 CFR. § 107, 171, 172 and potentially
174, 176, or 177: United States Department of Transportation rules apply to the
transportation of hazardous materials, and include the procedures for the packaging,
labeling, manifesting, and transporting of hazardous materials.
•
Stormwater Management Rules, N.J.A.C. 7:8-2.2 and Subchapter 5: These
regulations establish the design and performance standards for stormwater
management measures.
•
Water Quality Certification, Section 401 of the CWA, 33 U.S.C § 1341: The CWA
requires that applications for permits and licenses for any activity resulting in a
discharge to navigable water include certification that the discharge will comply with
applicable water quality and effluent standards. In accordance with CERCLA Section
121(e)(1), no federal, state, or local permits are required for remedial actions that are
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conducted entirely on site, although remedial actions must comply with the
substantive requirements of CWA Section 401.
•
New Jersey Pollutant Discharge Elimination System (NJPDES) Rules, N.J.A.C.
7:14A, (Subchapters 4.4, 5.3, 6.2, 11.2, 12.2, 13, 21.2 and Appendix B of chapter 12):
This chapter regulates the direct and indirect discharge of pollutants to the surface
water and ground water of New Jersey. It presents a list of effluent standards for site
remediation projects, and includes rules for land application permits, residual transfer
stations, and stormwater discharge information. In accordance with CERCLA
Section 121(e)(1), no federal, state, or local permits are required for remedial actions
that are conducted entirely on site, although remedial actions must comply with the
substantive requirements of the NJPDES rules.
•
New Jersey Technical Requirements for Site Remediation, N.J.A.C 7:26E-1.13, -2.1,
-2.2, -3.4, -3.8, -3.11, -4.5 and -4.7: These regulations identify the minimum technical
requirements that must be followed in the investigation and remediation of any
contaminated sites in New Jersey. Both numeric and narrative standards for
remediation of groundwater and surface water are listed.
•
Federal/State Pretreatment Standards, 40 CFR. § 403, and more stringent
requirements enacted by State or local law: These standards provide pretreatment
criteria that waste streams must meet prior to discharge to Publicly Owned Treatment
Works (POTW).
•
National Ambient Air Quality Standards (40 CFR. § 50): The Clean Air Act requires
USEPA to set standards for pollutants considered harmful to public health and the
environment. Standards are established for six primary and secondary pollutants.
•
New Jersey Air Pollution Control Rules, N.J.A.C. 7:27: The chapter governs
emissions that introduce contaminants into the ambient atmosphere for a variety of
substances and from a variety of sources.
2.4
DEVELOPMENT OF PRELIMINARY REMEDIATION GOALS
Generally, PRGs that are protective of human health and the environment are developed
early in the RI process based on readily-available screening levels for human health and
ecological risks. Since there are no chemical-specific ARARs that pertain to sediments,
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risk-based concentrations that are protective of fish consumption and associated
concentrations in sediment, that are protective of benthic organisms and wildlife, and
based on background concentrations were developed for this FFS.
2.4.1
Human Health Preliminary Remediation Goals
Human Health PRGs were developed consistent with USEPA Risk Assessment Guidance
for Superfund (RAGS) Part B (USEPA, 1991b) and based on the results of the human
health risk assessment (HHRA) presented in Appendix C “Risk Assessment.” The
process used to identify contaminants of potential concern (COPCs) and contaminants of
potential ecological concern (COPECs) is described in Attachment 4 of Appendix C.
Details on PRG development methods, data, and assumptions are presented in Appendix
B “Sediment TBCs and Development of Preliminary Remediation Goals.” Human health
PRGs were developed for COPCs with individual cancer risks above 10-4 (i.e., one in
10,000):
•
PCDD/F as toxic equivalent quotient (TEQ) [TCDD TEQ (D/F)].
•
PCB as Total PCB (sum of Aroclors).
•
PCB dioxin-like congeners evaluated as TCDD TEQ (PCB).
PRGs were also developed for COPCs with individual noncarcinogenic health hazards
above a hazard index (HI) of 1.0:
•
Total PCB (sum of Aroclors).
•
Total Chlordane.
•
Methyl mercury.
The methods, data, and exposure assumptions used to calculate the risk-based PRGs for
the protection of human health are described in Appendix B “Sediment TBCs and
Development of Preliminary Remediation Goals.” The PRGs developed for the adult
angler who consumes fish or crabs from the Lower Passaic River are summarized in
Table 2-2. For the analysis, the point of departure for cancer risks was calculated at 10-6
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(i.e., one in a million) and for non-cancer health hazards the point of departure was a HI
equal to 1.
Table 2-2: Summary of the PRGs Developed for Fish/Crab Tissue
COPC
PRGsa for Fish/Crab Tissue for an Adult Angler
Cancer PRGs (ng/g)
Non-cancer PRGs
-6
-5
-4
(ng/g)
1x10
1x10
1x10
TCDD TEQ
0.000055
0.00055
0.0055
NDb
Total PCB
4.1
41
410
56
Chlordane
23
230
2,300
1,407
Methyl mercury
NDc
281
ng/g – nanograms per gram of sediment
ND – not determined.
a: Assumes 40 eight-ounce fish or crab meals per year for 24 years.
b: No toxicity values are available at this time.
c: Classification - There is no quantitative estimate of carcinogenic risk from oral exposure.
When available data indicate that a COPC is associated with both carcinogenic and
noncarcinogenic health hazards, as is the case for Total PCB, PRGs were calculated for
both. Since PCBs have both carcinogenic risk and non-cancer health hazards, both health
endpoints are considered in selecting the PRGs. Based on the available toxicity data, a
PRG based on carcinogenic effects was calculated for Total PCB, but not for the TCDD
TEQ (PCB), because: (1) the estimated risks for Total PCB and TCDD TEQ (PCB) are
comparable, so that calculated PRGs using Total PCB and coplanar PCB congeners
separately would not significantly differ; and (2) any remedial action based on total PCB
PRGs would address the presence of the dioxin-like PCB congeners based on co-location.
The fish-tissue PRGs presented in Table 2-2 were based on an adult fish consumption
rate of 25 g/day or 40 eight-ounce fish meals per year. Appendix B “Sediment TBCs and
Development of Preliminary Remediation Goals” discusses PRGs calculated for other
fish-meal frequencies associated with New Jersey fish consumption advisory levels.
Sediment concentrations required for fish to meet the risk-based concentration levels
were estimated by dividing the tissue concentrations by a chemical-specific
bioaccumulation factor (BAF). The estimated risk-based sediment concentrations are
presented in Table 2-3. BAFs were derived as the ratio of biota (i.e., fish and crab) tissue
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concentration to sediment concentration. A detailed description of how the BAFs were
derived is provided in Section 7.0 of Appendix C “Risk Assessment.”
Table 2-3: Summary of the PRGs Developed for Sediment
COPC
PRGsa for Sediment
Cancer PRGs (ng/g)
Non-cancer PRGs
-6
-5
-4
(ng/g)
1x10
1x10
1x10
2,3,7,8-TCDD
0.00027
0.0027
0.027
NDb
Total PCB
1.03
10.3
103
14
Chlordane
1.2
12.0
119
72
Mercury
NDc
2,814
ND – not determined.
a: Assumes 40 eight-ounce fish or crab meals per year for 24 years.
b: No toxicity values are available at this time.
c: Classification - There is no quantitative estimate of carcinogenic risk from oral exposure.
2.4.2
Ecological Preliminary Remediation Goals
Ecological risk PRGs were developed consistent with USEPA Risk Characterization
Program (USEPA, 1997) and based on the results of the ecological risk assessment
(ERA) presented in Appendix C “Risk Assessment.” Sediment and fish tissue ecological
PRGs were developed for all COPECs identified in the FFS COPEC screening process
documented in Attachment 4 of Appendix C “Risk Assessment”. COPECs include
copper, lead, mercury (including methyl mercury), low-molecular weight PAH (LPAH)
and high-molecular weight PAH (HPAH), Total PCB (sum of Aroclors), Total DDx [sum
of dichlorodiphenyldichloroethane (DDD), dichlorodiphenyldichloroethylene (DDE), and
(dichlorodiphenyltrichloroethane) DDT isomers], dieldrin, TCDD TEQ (D/F), 4 , and
PCB dioxin-like congeners evaluated as TCDD TEQ (PCB).
The methods, data, and assumptions used to calculate the ecological receptor PRGs are
described in detail in Appendix B “Sediment TBCs and Development of Preliminary
Remediation Goals.” Table 2-4 presents the ecological PRGs for the selected sediment
4
Consistent with the Toxic Equivalency approach (Tillitt, 1999), the toxicological basis for the PRGs for
PCDD/F and coplanar PCB compounds is 2,3,7,8-TCDD. TCDD TEQ refers to the combined equivalency
associated with all Aryl hydrocarbon receptor (AhR) mediated toxicity.
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COPECs for each category of receptor considered in the ERA. The overall ecological
PRG is the lower of the two values. The fish tissue PRGs presented in Table 2-5 include
results of the residue-based (fish) and dose-based (wildlife) analyses conducted as part of
the ERA.
Table 2-4: Summary of Sediment PRGs for Ecological Receptors
Chemical
Units
Sediment PRGs
Benthosa
Wildlifeb
Lowest
Inorganics
Copper
ng/g
34,000
13,318
Wildlife PRG
Lead
ng/g
46,700
10,606
Wildlife PRG
Mercury
ng/g
150
37
Wildlife PRG
PAHs
Low Molecular Weight PAHs
ng/g
552
NOAA ER-L
High Molecular Weight PAHs
ng/g
1700
NOAA ER-L
PCB Aroclors
Total PCBs
ng/g
22.7
365
NOAA ER-L
Pesticides/Herbicides
DDx
ng/g
1.58
19
NOAA ER-L
Dieldrin
ng/g
0.02
271
NOAA ER-L
Dioxins/Furans
TCDD TEQc
ng/g
0.0032
0.0025
Wildlife PRG
q: ER-L = Effects Range-Low from Long et al. (1995), except where noted.
b: Derived as described in the FFS COPEC Screening Technical Memorandum (Appendix B).
c: Benthic benchmark for 2,3,7,8-TCDD derived by USFWS using sediment chemistry for Newark Bay and
oyster effect data presented in Wintermyer and Cooper (2003); wildlife value from USEPA (1993).
Table 2-5: Summary of Fish Tissue PRGs for Ecological Receptors
Chemical
Units
Fish Tissue PRGs
a
Lowest
b
Fish
Wildlife
Inorganics
Copper
ng/g
6.3
21,935
Fish
Lead
ng/g
88
700
Fish
Mercury
ng/g
19
40
Fish
PAHs
Low Molecular Weight PAHs
ng/g
89
Fish
High Molecular Weight PAHs
ng/g
89
Fish
PCB Aroclors
Total PCBs
ng/g
7.9
676
Fish
Pesticides/Herbicides
DDx
ng/g
0.3
147
Fish
Dieldrin
ng/g
35
487
Fish
Dioxins/Furans
TCDD TEQc
ng/g
0.050
0.0007
Wildlife
a. Based on critical body residuals (CBRs) as summarized in Appendix C “Risk Assessment”.
b. Derived as described in the FFS COPEC Screening Technical Memorandum (Appendix C, Attachment 2);
lowest of mammal and avian values.
c. Low risk fish concentrations for 2,3,7,8-TCDD from USEPA (1993).
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2.4.3
Identification of Background Concentrations
According to contaminated sediment remediation guidance, project managers should
consider background contributions to sites to adequately understand contaminant sources
and establish realistic risk reduction goals (USEPA 2005). The contaminated sediments
in the Lower Passaic River are located within a setting of interconnected waterways,
including the Passaic River above the Dundee Dam, tidal exchanges with Newark Bay,
and tributaries. These interconnected waterways need to be evaluated because they could
continue to contribute contaminants to the Lower Passaic River following the
implementation of a remedial alternative. This is particularly relevant to the achievement
of remediation goals (e.g., long-term effectiveness and permanence), since USEPA
(2002b) stipulates that “… the CERCLA program, generally, does not clean up to
concentrations below natural or anthropogenic background levels.”
The Draft Geochemical Evaluation (Step 2) (Malcolm Pirnie, 2006) examined sediment
contaminant concentration gradients from the mouth of the Lower Passaic River into the
Newark Bay Study Area (NBSA). Sediment contaminant concentrations generally
decrease by an order of magnitude from north to south, from the Lower Passaic River
into the NBSA. These data indicate that tidal exchange between the Lower Passaic River
and NBSA currently results in the net transport of contaminants from the Lower Passaic
River to Newark Bay. The NBSA RI/FS itself was initiated based on the concern that
contaminants related to the 80 Lister Avenue site on the Lower Passaic River had
impacted Newark Bay (USEPA 2004). Remediation of sediment contamination in the
Lower Passaic River is expected to reduce these impacts, causing sediment contaminant
concentrations in the NBSA to subsequently trend towards the concentrations of solids
transported into the NBSA from the Arthur Kill and the Kill Van Kull. From this it can
be inferred that NBSA sediments (and by extension, New York Harbor sediments) are too
closely related to contamination in the Lower Passaic River to be considered as a
potential “background” for the FFS.
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Investigation of sediment contaminant concentrations in the Upper Passaic River above
the Dundee Dam has revealed the presence of historic and ongoing upstream sources of
inorganics, pesticides, and Total PCB that are significant in comparison to contaminant
concentrations in the Lower Passaic River. USEPA (2002b) defines “background” as
constituents and locations that are not influenced by releases from the site and includes
both anthropogenic and naturally derived constituents. The physical boundary of the dam
isolates the proximal Dundee Lake and other Upper Passaic River sediments from any
Lower Passaic River influences. The proximity of these sediments to the proposed
remediation area and demonstrated geochemical connection to a portion of the Lower
Passaic River sediment contamination strongly argues in favor of their consideration as
representative of “background” for the Lower Passaic River. The chemistry in these
sediments is representative of the burden carried by the Upper Passaic River’s suspended
solids; therefore the deposited sediments record the background load to the Lower
Passaic River. The Role of Background in the CERCLA Cleanup Program (USEPA,
2002b) explains that CERCLA sites generally do not set cleanup levels below
acknowledged anthropogenic-derived COPC and COPEC background concentrations. In
cases where background contamination may pose risks, other programs or regulatory
authorities may be appropriate to address the sources, particularly those that are
anthropogenic.
Table 2-6 lists the concentrations of COPC and COPEC detected in a sediment core top
collected above Dundee Dam. Using geochemical principles discussed in Appendix A
“Conceptual Site Model,” the chemicals found in the core top are interpreted to represent
the current water column solids contaminant concentrations being introduced to the
Lower Passaic River from the Upper Passaic River. The chemical mass contributed with
the solids load from the Upper Passaic River represents a significant source of all of the
COPCs and COPECs, except 2,3,7,8 TCDD, and can be considered the background to the
Lower Passaic River.
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Table 2-6: Background COPEC and COPC Concentrations
Inorganics
Copper
Lead
Mercury
PAHs
LPAH
HPAH
PCB Aroclors
Total PCB
Pesticides/Herbicides
Total DDx
Dieldrin
Chlordane
PCDD/F
2,3,7,8-TCDD
Units
2007
(Background)
ng/g
ng/g
ng/g
80,000
140,000
720
ng/g
ng/g
8,900
65,000
ng/g
650
ng/g
ng/g
ng/g
91
4.3
92
ng/g
0.002
Because of this contaminant load, any remedial effort within the Lower Passaic River can
only be expected to meet the risk-based PRGs once the load from above the dam also
meets the PRGs. The load from the Upper Passaic River can be considered a baseline
that represents the maximum concentration that would be expected in the postremediation Lower Passaic River (dilution from other, less-contaminated sediment
sources would cause the concentrations in the Lower Passaic River to be less than what is
contributed over the dam).
2.4.4
PRG Selection
A single PRG for each contaminant was selected to guide the analysis of target areas and
alternatives for remediation using the nine Superfund evaluation criteria. In accordance
with EPA risk assessment guidance (Part B, Development of Risk-Based Preliminary
Remediation Goals, USEPA 1991), the point of departure for the selection of PRGs is a
risk level of 10-6 and a non-cancer Hazard Index = 1 for protection of human health and
the lower of the two ecological PRGs set to protect benthic organisms and wildlife at a
hazard quotient of one. However, EPA guidance entitled “Role of Background in the
CERCLA Cleanup Program (USEPA, 2002b) provides that “… the CERCLA program,
generally, does not clean up to concentrations below natural or anthropogenic
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background levels.” As presented in Table 2-7 (attached), current background levels for
all of the contaminants are above the human health PRG that represents the 10-6 risk
level, non-cancer Hazard Index = 1, and the lower ecological PRG (or as many of these
values which have been developed). Therefore, the target areas and alternatives will be
evaluated against the current background levels as represented by the recently deposited
sediments from a core collected from the Upper Passaic River in the stretch immediately
above Dundee Dam.
However, as discussed in Table 2-7, the background levels for many of the contaminants
pose unacceptable risks, in part resulting from continuing contributions from upstream
sources. Thus, while the Source Control Early Action addresses the contaminated
sediments of the lower eight miles of the Passaic River, a separate source control action
will need to be implemented above Dundee Dam to identify and reduce or eliminate those
background sources. Such a separate action might include identifying facilities above the
dam with on-going contributions to the Upper Passaic River, or conducting a track-down
program where samplers are placed further and further upstream until contaminants are
tracked back to specific industrial or municipal sources. Such sources would then be
controlled through federal or State of New Jersey regulatory programs.
2.5
IDENTIFICATION OF POTENTIAL TARGET AREAS FOR
REMEDIATION
When developing remedial alternatives, it is necessary to identify the sediments that
might be appropriately targeted for remediation to meet the RAOs. Criteria for making
this identification typically include ARARs, RBCs, and PRGs, as well as geochemical
and statistical interpretations of contaminant concentration data and sediment
characteristics. The six active remedial alternatives (aside from the No Action
alternative) developed in Section 4.0 “Development of Remedial Action Alternatives”
will be applied to the target area identified below.
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2.5.1
Target Area Identification Analyses
In an effort to identify distinct areas that, if remediated, may result in the achievement of
RAOs, a series of geospatial and geochemical analyses were conducted as described
below. More information on the methodologies used and the results obtained for each of
the analyses is presented in Appendix A “Conceptual Site Model.”
2.5.1.1
Primary Erosional Zone
As discussed in the CSM, tidal currents continuously cause surface sediments to
resuspend. Once suspended, sediments are significantly homogenized prior to
deposition. Given these observations, an analysis was conducted to attempt to discern the
existence of highly erosive areas which might have relatively greater influence on the
nature, extent, and/or degree of contamination present in suspended sediments.
Data obtained during eight bathymetric surveys conducted between 1989 and 2004 were
used to generate eight interpolated surfaces, each representing the sediment surface at the
time of a survey. These surfaces were then compared against one another, and
information was obtained regarding the net annual rate of erosion and deposition in the
surveyed areas during the timeframe encompassed by the surveys. The results of this
comparison identified certain bands within the Area of Focus which were consistently or
occasionally erosional on a net annual basis during the timeframe encompassed by the
surveys. The results of this comparison are shown in Figure 2-1.
A plot of river mile versus the proportion of area that is consistently or occasionally
erosional is shown in Figure 2-2. Inspection of this plot shows that the major peaks (i.e.,
where the proportion of area that is consistently or occasionally erosional is greater than
10 percent) are found between RM3.7 and RM5.3 (RI/FS RM3.5 and RI/FS RM5.1). A
boundary was drawn around the consistently and occasionally erosional areas within
these limits to define the Primary Erosional Zone. This boundary was adjusted based on
engineering judgment to create an area amenable to potential remedial actions. The total
area of the Primary Erosional Zone is approximately 68 acres.
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2.5.1.2
Primary Inventory Zone
As discussed in the CSM, contamination in the Area of Focus is well mixed. At any time
horizon within the sediment bed, concentrations are constrained within a narrow range
regardless of location. With this characteristic in mind, the variation in contaminant
inventory from one location to another is influenced more by the difference in thickness
of the sediment deposit than by any difference in the magnitude of contaminant
concentrations at either location.
The metric of mass per unit area (MPA) is a measure of the mass of a contaminant
contained beneath a unit area of the sediment surface, and typically has units of grams per
square meter. For the purposes of this evaluation, given the well-mixed nature of
contamination, MPA is considered a suitable metric to quantify inventory at a given
location. Calculations of MPA for coring locations throughout the river were presented
in the Draft Geochemical Evaluation (Step 2) (Malcolm Pirnie, Inc., 2006) and are
discussed in Appendix A “Conceptual Site Model.”
In order to determine if certain areas in the river contain a relatively higher amount of
inventory, a plot of river mile versus weighted curve sediment inventory was prepared
(Figure 2-3). From this plot, it can be seen that the area between RM2.6 and RM3.5
(RI/FS RM2.4 and RI/FS RM3.3) contains the highest inventory for the contaminants
analyzed. A boundary created around these limits was adjusted based on engineering
judgment to identify an area amenable to potential remedial actions. This area, which is
referred to as the Primary Inventory Zone, covers approximately 63 acres.
2.5.1.3
Area of Focus
As discussed in Section 2.6 “Risk Reduction Resulting from Remediation of Identified
Target Areas,” risk reduction anticipated to result from remediation of either the Primary
Inventory Zone, Primary Erosional Zone, or both were not adequate; hence, the Area of
Focus is selected. This includes the entire (bank-to-bank) river area from RM0 to RM8.3
(RI/FS RM8.0), which contains elevated COPC and COPEC concentrations in surface
sediment and contaminant inventory that is at risk of being eroded and transported over
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time due to high flow events as well as typical flow and tidal conditions. This
contaminant transport is likely to interfere with natural recovery of the Lower Passaic
River and Newark Bay and other contiguous water bodies. The Area of Focus
encompasses both the Primary Erosional Zone and the Primary Inventory Zone, and the
remaining fine-grained sediment below RM8. As discussed in Appendix A “Conceptual
Site Model,” there is a natural constriction in the Lower Passaic River at about RM8 and
the river widens and slows considerably downriver of that point. For these reasons the
majority of fine-grained sediment exists below this point. Small areas of fine-grained
sediment accounting for about 11 percent of the total fine-grained sediment area do occur
above RM8. However, these deposits are much thinner than the sediments below RM8
and represent much smaller risk than the fine-grained sediment deposit below RM8. The
Area of Focus covers approximately 650 acres.
2.5.2
Estimation of Future Concentration in Surface Sediments
Future concentrations of COPCs and COPECs in the Lower Passaic River surface
sediments were estimated using an empirical method. First an empirical mass balance
was developed to quantify the contributions of the various solids and contaminant sources
to the sediment present in the Lower Passaic River, such as sediment re-suspension, the
Upper Passaic River, tributaries, CSOs/SWOs, and tidal exchange with Newark Bay.
For several of the COPCs and COPECs, simple forecasting was sufficient to estimate the
future concentration. “Simple forecasting” entails an examination of contaminant levels
in the dated sediment cores (high resolution cores) over the period approximately 1980 to
2005 to establish an approximate rate of decline (usually expressed as an exponential
decay rate, or half-life). This rate of decline, or trajectory, was then assumed to hold
indefinitely into the future as a basis to estimate future sediment concentrations. For
Monitored Natural Recovery (MNR), simply projecting the concentration decline curve
into the future predicts the concentration at a given time. For remedial scenarios, the rate
of decline was applied to a revised estimate of COPC and COPEC concentrations surface
sediment based on the empirical mass balance, adjusted for the remedial scenario (e.g.,
capping of the Area of Focus reduces the resuspension contribution to the overall
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contamination). The estimate of the amount of reduction is dependent on the relative
proportions of the contaminant in the subsurface sediments of the Lower Passaic River
and in the various external solids sources as determined by the mass balance. The
empirical mass balance and contaminant concentration projections are described in detail
in Appendix D “Empirical Mass Balance Model” and Table 2-8.
Table 2-8: Prediction Process for Concentrations in Surface Sediment for the Risk Assessment
Compound
Forecast Basis
Metals
Copper
Simple forecast.
Lead
Simple forecast.
Mercury
Simple forecast.
PAHs
LPAH
Simple forecast (note that current observations suggest no trend or a slightly increasing
trend with time).
HPAH
Simple forecast (note that current observations suggest no trend or a slightly increasing
trend with time).
PCB
Total PCB (sum
Simple forecast of the sum of PCB congeners as a surrogate for the sum of Aroclors. The
Aroclors)
ratio of the sum of PCB congeners to the sum of Aroclors was based on an analysis of the
2006 USEPA low resolution core data.
TCDD TEQ (PCBs)
Simple forecast of the sum of congeners as a surrogate for the sum of PCBs with TCDD
TEQs. The ratio of the sum of congeners to the sum PCB TEQ was based on an analysis
of the 2006 USEPA high resolution core data. For the MNR scenario, this ratio was
assumed to remain unchanged with time. For the remedial scenarios, the PCB TEQ for
the major solids sources (Dundee Dam and possibly Newark Bay) was examined to
estimate a PCB TEQ ratio for the Lower Passaic River after remediation. Once
established post-remediation, this ratio is assumed to be unchanged with time and the
PCB TEQ simply tracks the sum of PCB congeners forecast.
Pesticides/Herbicides
Chlordane
Simple forecast (note that current observations suggest no trend or a slightly increasing
trend with time).
Dieldrin
Simple forecast (note that current observations suggest no trend or a slightly increasing
trend with time).
4,4’-DDE
Simple forecast.
4,4’-DDD
A simple forecast of DDE as a surrogate for DDD. The ratio of DDD to DDE was based
on an analysis of the 2005 USEPA high resolution core data. Alternatively, the sum of
DDD and DDE was checked as an alternative basis for forecasting.
4,4’-DDT
A simple forecast of DDE as a surrogate for DDT. The ratio of DDT to DDE was based
on an analysis of the 2005 USEPA high resolution core data.
Total DDx
A simple forecast of DDE as a surrogate for Total DDx. The ratio of Total DDx to DDE
was based on an analysis of the 2005 USEPA high resolution core data.
PCDD/F
TCDD TEQ (D/F)
A simple forecast of 2,3,7,8-TCDD as a surrogate for the TCDD TEQs. The ratio of
2,3,7,8-TCDD to the sum TCDD TEQs was based on an analysis of the 2005 USEPA
high resolution core data. For the MNR scenario, this ratio was assumed to remain
unchanged with time. For the remedial scenarios, the TCDD TEQ for the major solids
sources (Dundee Dam and possibly Newark Bay) were examined to assess whether an
alternate TCDD TEQ ratio will exist in the Lower Passaic River after remediation. Once
established post-remediation, this ratio was assumed to be unchanged with time and the
TCDD TEQ trajectory simply tracks the 2,3,7,8-TCDD forecast.
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Table 2-9 presents the projected concentrations in 2048 for the No Action alternative, for
active remediation of the Area of Focus, and for active remediation of the Primary
Erosional Zone and Primary Inventory Zone. Table 2-9 also presents percent reductions
between 2018 and 2048. The year 2018 is an assumed completion of remediation date,
approximately ten years from the time of writing this document. Table 2-10 shows the
predicted COPC and COPEC concentrations in 2048 in comparison to the Upper Passaic
River background concentrations.
Table 2-10: Forecasted Concentrations in Surface Sediment Compared to Background Concentrations from
the Upper Passaic River
Analyte
Upper Passaic River
Forecasted 2048
Forecasted 2048
Sediment Background Concentration Primary
Concentration
Concentrations
Erosion Zone
Area of Focus
Mercury (mg/kg)
0.72
0.22
0.17
Lead (mg/kg)
140
65
60
Copper (mg/kg)
80
41
38
Total Chlordane (μg/kg)
92
36
36
DDE (μg/kg)
26
8.0
5.7
DDD (μg/kg)
59
11
7.9
DDT (μg/kg)
6.8
2.4
1.7
Total DDT (μg/kg)
91
22
15
Dieldrin (μg/kg)
4.3
3.9
3.4
2,3,7,8-TCDD (ng/kg)
2.0
32
6.5
PCDD/F TEQ (μg/kg)
0.002
0.032
0.0066
Total PCB (μg/kg)
660
84
64
PCB TEQ Mammal (μg/kg)
0.014
0.0017
0.0013
PCB TEQ Bird (μg/kg)
0.151
0.026
0.020
PCB TEQ Fish(μg/kg)
0.001
0.00014
0.00011
LMW PAH (mg/kg)
8.9
5.3
5.2
HMW PAH (mg/kg)
65
35
35
Concentrations rounded to two significant figures, whenever possible
2.6
RISK REDUCTION RESULTING FROM REMEDIATION OF
IDENTIFIED TARGET AREAS
2.6.1
Human Health Risk Assessment Summary
The HHRA evaluated potential risk to human health from eating fish and crab. The
HHRA is presented in detail in Appendix C “Risk Assessment.” Cancer risks and noncancer health hazards were evaluated for a RME to assist in the decision-making process,
consistent with the NCP (USEPA, 1990). For purposes of establishing current risks and
comparing the relative risk reductions after remedial alternatives are implemented, cancer
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risks were estimated for a combined adult/child receptor (6 years as a child and 24 years
as an adult) and non-cancer health hazards were estimated for a child and adult receptor.
The exposure duration for the combined adult/child of 30 years is used to represent the
most conservative standard receptor for evaluation of carcinogens. The cancer risks
derived in the HHRA are compared to the NCP risk range of 10-4 (one in ten thousand) to
10-6 (one in a million) and non-cancer threshold of 1 (USEPA, 1991b). The HHRA used
the same set of COPCs and the same risk assessment methodology, including potential
exposure scenarios and assumptions that were evaluated in the current risk evaluation
described in Appendix C “Risk Assessment” and discussed in Section 2.4 “Development
of Preliminary Remediation Goals.” Results from the current risk evaluation were then
used as a baseline to assess the relative risk reduction afforded by the No Action
alternative, by active remediation of the Area of Focus, or by active remediation of the
Primary Erosional Zone and Primary Inventory Zone. Table 2-11 presents a summary of
these results.
Table 2-11: Summary of Baseline and Future Cancer Risk and Non-cancer Health Hazards and the
Relative Reductions in Risk/Hazard after 30 Years
Fish Consumption
Time
Adult + Child
Adult
Child
Relative Reductionc
d
Period
Combined Risk Hazard Hazard Combined
Adult
Child
Risk
Hazard
Hazard
2018
No Action
Alternativea
6x10-3
2019-2025
4x10
2018
Active Remediation
2019-2025
of Area of Focus
4x10-3
2x10
1x10-2
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63%
63%
69%
69%
89%
NDf
67%
67%
72%
71%
91%
NDf
75%
75%
79%
78%
92%
NDf
64%
f
7
ND
21
33
18
29
58%
75%
f
6
ND
16
25
14
22
91%
-4
2042-2048
Baselinee
20
42%
-3
9x10-4
5x10
37
-3
2042-2048
2018
Active Remediation
of Primary
Erosional
2019-2025
Zone/Primary
Inventory Zone
2042-2048
24
95%
f
5
ND
64
99
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Table 2-11continued: Summary of Baseline and Future Cancer Risk and Non-cancer Health Hazards and
the Relative Reductions in Risk/Hazard after 30 Years (continued)
Crab Consumption
Time
Adult + Child
Adult
Child
Relative Reductionc
d
Period
Combined Risk Hazard Hazard Combined
Adult
Child
Risk
Hazard
Hazard
2018
No Action
Alternative
4x10-3
2019-2025
3x10
2018
Active Remediation
2019-2025
of Area of Focus
3x10-3
2x10
27
5
NDf
17
28
14
24
5
NDf
13
21
11
19
4
NDf
2x10-2
86
140
78%
77%
78%
81%
81%
94%
NDf
80%
80%
83%
83%
94%
NDf
85%
85%
87%
87%
95%
NDf
87%
84%
91%
-4
2042-2048
Baselinee
16
-3
8x10-4
4x10
31
-3
2042-2048
2018
Active Remediation
of Primary
Erosional
2019-2025
Zone/Primary
Inventory Zone
2042-2048
19
96%
98%
a: Detailed discussion of the remedial alternatives is provided in Section 2.5.1 “Target Area Identification
Analyses.”
b: The approach used to estimate risk/hazard for human receptors is provided in Appendix C “Risk
Assessment.”
c: Baseline conditions compared to estimated condition 30 years following implementation.
d: The time period 2018 represents the year remediation is expected to be complete and the predicted
average annual concentrations at 2018 are used as the EPCs. For 2019-2048, the predicted average annual
concentrations derived from years 2019 through 2048 are used to derive an average concentration over the
total exposure duration of 30 years (i.e., 6 years as a child and 24 years as an adult). Thus, a 6-year average
of the average annual sediment concentrations is used for the child, and a 24-year average of the average
annual sediment concentrations is used to represent the adult for cancer exposure only.
e. The current scenario is assumed to represent the risks in 2007, before remediation is initiated and prior to
accounting for natural degradation (e.g., monitored natural recovery). Current risk represents the RME as
described in Section 5.3.1 and provided in Attachment 4 of Appendix C, Tables 4-16 and 4-18.
f. ND – not determined. Only the adult receptor is evaluated for non-cancer health hazards for the 20422048 time period to assist risk management decisions regarding the selection of a remedial action. The
health hazard for the adult, rather than the child, may be more heavily relied upon for risk management
decisions because datasets supporting the ingestion rates are available for an adult, but not a child receptor.
The results of the baseline HHRA indicate that current cancer risks and non-cancer health
hazards exceed the NCP criteria for consumption of fish and crab and support the need
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for remedial action. With respect to the evaluation of future remedial scenarios, the total
risk/hazard levels are still above the NCP criteria for the No Action alternative and active
remediation in the Primary Erosional Zone and Primary Inventory Zone. However, the
total cancer risk estimated for active remediation of the Area of Focus is at the upper end
of the NCP risk range 30 years following remediation (i.e., by 2048). In addition, the
active remediation alternatives rely in monitored natural recovery and institutional
controls to achieve the NCP risk range in future years. Also, separate source control
actions above Dundee Dam, when implemented, will shorten the time frame within which
the active remediation alternatives achieve the risk range. Note also that active
remediation of the Area of Focus resulted in the greatest reduction in risk/hazard. The
HHRA was conducted consistent with USEPA guidance (RAGS Part D, USEPA 2001a),
guidelines, and policy, and the uncertainties associated with the risk/hazard estimates are
discussed in the HHRA (Appendix C “Risk Assessment”).
2.6.2 Ecological Risk Assessment Summary
The ERA conducted to support the FFS evaluated direct contact exposures by sedimentassociated receptors to contaminated sediment. In addition, the bioaccumulation hazards
to aquatic organisms that forage in the Lower Passaic River and the wildlife that consume
them were evaluated. Receptors of interest include sediment-dwelling and epibenthic
macroinvertebrates, pelagic and demersal fish, and piscivorous wildlife (mink and great
blue heron).
A chemical screening process was used to select nine COPEC for consideration,
including copper, lead, mercury, LPAH, HPAH, dieldrin, Total DDx, Total PCB, and
TCDD TEQ, including contributions from PCDD/F and PCB congeners. Screening level
exposure assumptions were used to model dietary exposures and protective toxicity
values [e.g., NOAA effects range-low (ER-L) concentrations, low end, no observedadverse-effects levels (NOAEL), lowest observed-adverse-effects levels (LOAEL),
critical body residues (CBR), and ingestion toxicity data] to ensure that potential
ecological hazards were conservatively estimated in the assessment.
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The process of evaluating remedial alternatives to address ecological concerns employed
the same risk assessment methodology, including potential exposure scenarios and
toxicological data used in the assessment of current conditions (presented in Section 6.0
of Appendix C “Risk Assessment”). Results from the assessment of current conditions
were then used to assess the relative risk reduction afforded by each of the remedial
scenarios evaluated. In addition, the relative risk reduction among the three scenarios
was examined. Incremental hazards (i.e., those above background) were not calculated
because necessary analytical data from above Dundee Dam were not available at the time
of report preparation.
Table 2-12 presents a summary of the geometric mean of the NOAEL and LOAEL HI
calculated for the evaluated receptors for current conditions and for each of the three
selected remedial scenarios. The geometric mean is used here to present the risk based
on a single effect level. These findings strongly support a conclusion that ecological
receptors that reside in the river currently are being adversely impacted as a result of
exposure to COPECs associated with the river sediment and biological tissue. With
respect to the evaluation of future remedial scenarios, the Area of Focus scenario resulted
in the greatest reduction in ecological hazards and ecological improvements are predicted
to occur in a substantially shorter period of time. None of the remedial scenarios would
result in a condition of no significant risk of harm for any of the ecological receptors over
the time periods assessed; however, by Year 2048, it is anticipated that wildlife receptors
would have a hazard reduction of 78 to 98 percent for remediation of the Area of Focus.
Again, separate source control actions above Dundee Dam, when implemented, will
accelerate the time frame within which the active remedial alternatives for the Area of
Focus will reach the condition of no significant risk of harm for the ecological receptors.
The ERA also determined that there were significant uncertainties with the benchmarks
used to screen sediment and biological tissue concentrations and that the potential
hazards associated with these endpoints were conservatively evaluated. Although a
Baseline Ecological Risk Assessment has not yet been completed, it is anticipated that the
potential hazards identified in this analysis will represent an upper bound to more
realistically-derived values.
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Table 2-12: Summary of Ecological Hazards Associated with Current Conditions and Various Remedial
Scenarios
Receptor/
Remedial Scenarioa
Baseline
Estimated Future
Hazard
Endpoint
Hazardb
Hazardb
Reductionc
2018
2048
Macroinvertebrates/sediment benchmarks
Monitored Natural Recovery
1,577
1,259
34%
1,898
Primary Erosional Zone/Primary Inventory Zone
1,388
1,160
39%
Area of Focus
383
326
83%
Macroinvertebrates/CBRsd
Monitored Natural Recovery
771
261
84%
1,665
Primary Erosional Zone/Primary Inventory Zone
612
220
87%
Area of Focus
199
78
95%
Fish (American eel/white perch)/CBRs
Monitored Natural Recovery
2,637
1,054
85%
6,858
Primary Erosional Zone/Primary Inventory Zone
2,373
955
86%
Area of Focus
1,215
497
93%
Fish (mummichog)/CBRs
Monitored Natural Recovery
703
302
56%
694
Primary Erosional Zone/Primary Inventory Zone
646
279
60%
Area of Focus
352
155
78%
Mammal (mink)/ingestion dose modeling
Monitored Natural Recovery
166
52
85%
339
Primary Erosional Zone/Primary Inventory Zone
121
34
90%
Area of Focus
22
6
98%
Bird (heron)/ingestion dose modeling
Monitored Natural Recovery
17
5
89%
49
Primary Erosional Zone/Primary Inventory Zone
14
4
92%
Area of Focus
6
2
96%
a: A detailed discussion of the remedial alternatives is provided in Section 2.5 “Identification of Potential
Target Areas for Remediation.”
b: The approach used to estimate ecological hazards is provided in Appendix C “Risk Assessment”. Where
bounding estimates of the hazards were derived, the geometric mean of the upper and lower bounds are
provided above.
c: Compared to baseline conditions after 30 years.
d: Critical Body Residues (CBR) are threshold tissue concentrations above which adverse effects have been
reported in the literature.
2.6.3
Comparison of Reduction of COPC and COPEC Concentrations
Given the natural processes that are occurring in the river, the concentrations of most
COPCs and COPECs will decline over time regardless of the method chosen for
remediation. However, based on the Empirical Mass Balance Model and concentration
projections discussed above, active remediation has a significant effect on how quickly
the recovery will occur as compared to MNR alone (Appendix D “Empirical Mass
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Balance Model”). Any chosen remediation goal will be achieved sooner by active
remediation than by MNR except for chemicals that have continuing sources external to
the river. Table 2-13 gives the reduction of time in years for each COPC and COPEC for
the Area of Focus alternative as compared to MNR.
Table 2-13: Time Difference between MNR Scenario and Area of Focus Scenario
Analyte
Mercury
Lead
Copper
Total Chlordane
DDE
DDD
DDT
Total DDT
Dieldrin
2,3,7,8-TCDD
PCDD/F TEQ
Total PCB
PCB TEQ Mammal
PCB TEQ Bird
PCB TEQ Fish
Total TEQ Mammal
Total TEQ Bird
Total TEQ Fish
LMW PAH
HMW PAH
The symbol (-) represents no time difference.
Time Difference (Years)
10
5
5
15
15
15
15
40
40
10
10
10
10
40
25
40
-
The concentrations of COPCs and COPECs in sediment selected as the PRG are based on
background concentrations found in recently deposited sediment above Dundee Dam (see
section 2.4.4 “PRG Selection” and Table 2-7). Given the projected declines in COPC
and COPEC concentrations due to the different remedial scenarios, an assessment can be
made of the PRG selected for each compound:
Copper: Copper is not a COPC for human health so human health thresholds were not
developed for comparison. The selected level may not immediately be protective of
benthos or wildlife although remediating the Area of Focus is anticipated to achieve
protective levels for benthos sometime after 2048 due to natural recovery processes.
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Lead: Lead is also not a COPC for human health so human health thresholds were not
developed for comparison. The selected level may not immediately be protective of
benthos or wildlife although remediating the Area of Focus is anticipated to achieve
protective levels for benthos sometime after 2048 due to natural recovery processes.
Mercury: Natural recovery alone would result in mercury concentrations below
background by approximately 2021 and non-cancer hazards below HI=1 for 40 fishmeals per year before 2018. Remediating the Primary Erosional Zone or the Area of
Focus would result in concentrations immediately achieving background levels or lower.
Cancer thresholds have not been developed for comparison. The selected level may not
be protective of benthos or wildlife, however remediating the Area of Focus may be
protective of benthos sometime after 2048 due to natural recovery processes, while
protection of wildlife would take somewhat longer.
LMW PAH: LMW PAH is not a COPC for human health or a COPEC for wildlife so no
thresholds were developed for comparison. A level that protects benthos is not likely
achieved by any scenario; however ecological exposures in remediated areas would be
consistent with background. The selected level is met by 2018 regardless of action.
HMW PAH: HMW PAH is not a COPC for human health or a COPEC for wildlife so no
thresholds were developed for comparison. A level that protects benthos is not likely
achieved by any scenario; however ecological exposures in remediated areas would be
consistent with background. The selected level is met by 2018 regardless of action.
Total PCB: The total PCB level protects human health at 6 meals per year (10-4 cancer
risk) or 1 meal per year (10-5 cancer risk and non-cancer HI), but may not protect benthos
or wildlife. The benthos and wildlife exposures would be consistent with background.
The selected level is met by 2018 regardless of action.
Total DDx: Total DDx is not a COPC for human health so thresholds were not
developed for comparison. The chosen level is not protective of benthos or wildlife
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although exposures would be consistent with background conditions. The selected level is
met by 2018 regardless of action.
Total Chlordane: The chosen Total Chlordane level protects human health at 40 meals
per year (10-4 cancer risk) or 12 meals per year (non-cancer HI). Total Chlordane is not a
COPEC for benthos or wildlife evaluation. The selected level is met by 2018 regardless
of action.
Dieldrin: Dieldrin is not a COPC for human health so no thresholds were developed for
comparison. The selected level is protective of wildlife, but not benthos. The selected
level is met by 2018 regardless of action.
PCDD/F: The selected PCDD/F level protects human health between 2 and 6 meals per
year at a 10-6 cancer risk, or at 40 meals per year for a 10-5 cancer risk. Non-cancer
thresholds were not developed for comparison. The selected level also protects benthos
and wildlife. The selected level is likely to be met sometime after 2048 if the Area of
Focus is remediated. Concentrations in the Area of Focus are projected to drop within the
human health risk range (10-4 for 40 meals per year) upon completion of active
remediation of the Area of Focus by 2018. Thresholds for benthos and wildlife will likely
be met sometime after 2048 (and before achieving background levels) assuming
remediation of the Area of Focus. No Action is projected to achieve any threshold 40
years later than active remediation of Area of Focus.
2.7
SELECTION OF TARGET AREA FOR REMEDIATION
The COPC and COPEC concentrations known to exist in the surface sediments of the
Area of Focus are clearly greater than the risk-based PRGs and the background
concentrations. For this reason a remedial strategy that can reduce the concentrations to
at least the level of background is necessary to begin to achieve the RAOs. The above
analyses considered the No Action alternative, active remediation of the Primary Erosion
Zone and the Primary Inventory Zone, and active remediation of the Area of Focus. The
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evaluations of risk, development of PRGs, and estimation of future concentrations were
used to evaluate the benefit of remediating each of the three target areas. Based on the
estimated risk reduction described in Section 2.6 “Risk Reduction Resulting from
Remediation of Identified Target Areas,” neither the No Action alternative nor the active
remediation of the Primary Erosional Zone and the Primary Inventory Zone will achieve
residual risks below the acceptable USEPA threshold within reasonable time frames. In
addition, sediment concentrations exceeding PRGs have been identified throughout the
Area of Focus, and active remediation of the Primary Erosion Zone and the Primary
Inventory Zone does not address these continuing contaminant sources. Active
remediation of the Area of Focus reduces the COPC and COPEC concentrations in the
surface sediments to within the background concentrations that are currently introduced
to the Lower Passaic River from the Upper Passaic River, reduces the human health risk
by 95 to 98 percent, and reduces the ecological hazard by 78 to 98 percent (refer to
Section 2.6 “Risk Reduction Resulting from Remediation of Identified Target Areas”),
which meets the RAO. Based on prediction of future surface concentrations generated
using the Empirical Mass Balance Model (Appendix D), active remediation of the Area
of Focus followed by MNR achieves any threshold for 2,3,7,8-TCDD, which is
responsible for about 65 percent of the risk, 40 years faster than it would be achieved by
MNR alone. The reduction of other COPCs and COPECs is also accelerated by the
remediation of the Area of Focus. For these reasons, the Area of Focus is the preferred
target area. Therefore, all active alternatives that are presented in Section 4.0
“Development of Remedial Action Alternatives” are developed to remediate the finegrained sediments of the lower 8 miles in their entirety.
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3.0
IDENTIFICATION AND SCREENING OF GENERAL
RESPONSE ACTIONS, REMEDIAL TECHNOLOGY CLASSES,
AND PROCESS OPTIONS
General response actions are categories of actions that may be implemented to achieve
the Study’s RAOs. This section identifies and screens general response actions, remedial
technology classes, and process options that are potentially applicable to a Source
Control Early Action to remediate contaminated sediment in the Area of Focus. The
technology selection and screening processes were conducted in accordance with the
Guidance for Conducting Remedial Investigations and Feasibility Studies Under
CERCLA (USEPA, 1988).
Various databases, technical reports, and publications (refer to Section 3.2 “Sources and
Methods for Identification of Potentially Applicable Technologies”) were used to conduct
a search to identify potentially applicable technologies based on the general response
actions identified below. The selected technology classes were then expanded into lists
of potentially applicable process options.
Ancillary technologies, such as sediment disposal options, sediment dewatering,
wastewater treatment, sediment transportation options and site restoration options are
discussed in Section 3.4 “Ancillary Technologies”.
It is important to note that screening processes were conducted solely for the purposes of
an early action within the Area of Focus. Technologies and process options were
identified, evaluated, and screened (resulting in retention or elimination) based on their
applicability for this purpose. The development of the feasibility study for the overall 17mile comprehensive Study may identify, evaluate, and screen a wider set of technologies.
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3.1
IDENTIFICATION OF GENERAL RESPONSE ACTIONS
The first step in the development and screening of alternatives is to identify general
response actions that may be taken to satisfy the RAOs for the FFS. The general
response actions identified are as follows:
•
No action.
•
Institutional controls.
•
MNR.
•
Containment.
•
In situ treatment.
•
Sediment removal.
•
Ex situ treatment.
•
Beneficial use of dredged sediment.
•
Disposal of dredged sediment.
A brief description of each of the general response actions is provided below.
3.1.1
No Action
Consideration of a No Action response is required by the NCP. The No Action response
serves as a baseline against which the performance of other remedial alternatives may be
compared. Under the No Action response, contaminated river sediment will be left in
place without treatment or containment. No additional institutional controls would be
implemented as part of the No Action alternative; however, it is assumed that existing
institutional controls would be continued.
3.1.2 Institutional Controls
Institutional controls are legal or administrative measures designed to prevent or reduce
human exposure to on-site hazardous substances. Fish consumption advisories and
dredging restrictions are examples of relevant institutional controls for the Lower Passaic
River. Institutional controls are typically implemented in conjunction with other remedy
components.
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3.1.3
Monitored Natural Recovery
Natural recovery refers to the decline in contaminant concentrations in impacted media
over time via natural processes that contain, destroy, or reduce bioavailability or toxicity
of contaminants. These naturally occurring mechanisms include physical phenomena
(e.g., burial and sedimentation), biological processes (e.g., biodegradation), and chemical
processes (e.g., sorption and oxidation). MNR includes monitoring, and may include
modeling, to assess the whether these natural processes are occurring and at what rate
they may be reducing contaminant concentrations, but does not include active remedial
measures. MNR may be an appropriate response action if natural recovery processes can
achieve site-specific RAOs in a time frame that is reasonable compared to other active
remedial measures. In addition, MNR may be used as one component of a total remedy,
either in conjunction with active remediation or as a follow-up measure to continue to
reduce contaminant concentrations.
3.1.4
Containment
Containment entails the physical isolation or immobilization of contaminated sediment,
for example, by an engineered cap. Assuming effective cap design and construction,
containment results in the isolation of contaminated sediment, thereby limiting potential
exposure to, and mobility and bioavailability of, contaminants bound to the sediment.
3.1.5
In Situ Treatment
In situ treatment technologies may be used to reduce contaminant concentrations without
removal or containment of the contaminated sediments. Some in situ processes, such as
stabilization and solidification, may reduce contaminant mobility or bioavailability.
3.1.6
Sediment Removal
Sediment removal may be accomplished by dredging or excavation of contaminated
sediment for subsequent treatment or disposal. This response results in the removal of
contaminant mass from the river bed.
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3.1.7
Ex Situ Treatment
Ex situ treatment involves the application of technologies to transform, destroy, or
immobilize contaminants following removal of contaminated sediments. Numerous ex
situ treatment options are available. After ex situ treatment, treated dredged sediment
could either be applied to a beneficial use or disposed on land or in water (if it meets
disposal criteria). Both of these general response actions are discussed below.
3.1.8
Beneficial Use of Dredged Sediments
Following removal and, if necessary, ex situ treatment, dredged material could potentially
be applied for a beneficial use. Sediment that meets applicable criteria for contaminant
concentrations and structural properties could serve a beneficial purpose such as
structural fill or lower permeability cover or cap for a brownfield or landfill without pretreatment. In some instances, ex situ treatment, such as ex situ immobilization, is
required prior to application of dredged sediment as fill or cover material. In addition,
certain ex situ treatment processes result in the formation of an end product that can be
beneficially used (e.g., formation of glass following vitrification, or formation of cement
aggregate following certain thermo-chemical processes).
3.1.9 Disposal of Dredged Sediments
The definition of ‘disposal’ used in the Contaminated Sediment Remediation Guidance
for Hazardous Waste Sites (USEPA, 2005) has been adopted for use here. Namely,
‘disposal’ refers to the placement of dredged or excavated material into a permanent or
temporary structure, site, or facility. Depending on the disposal location, the dredged or
excavated material may undergo limited or extensive prior treatment.
3.2
SOURCES AND METHODS FOR THE IDENTIFICATION OF
POTENTIALLY APPLICABLE TECHNOLOGIES
Several databases, guidance documents, and feasibility studies for similar sediment
remediation projects were used to identify potentially applicable remedial technologies.
The following sources are of particular note:
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•
Contaminated Sediment Remediation Guidance for Hazardous Waste Sites (USEPA,
2005).
•
Federal Remediation Technologies Roundtable (FRTR) website
(www.frtr.gov/matrix2/top_page.html).
•
USEPA Hazardous Waste Clean-up Information website (www.clu-in.org/).
•
Assessment and Remediation of Contaminated Sediments (ARCS) Program,
Remediation Guidance Document (USEPA, 1994).
•
Equipment and Placement Techniques for Subaqueous Capping (Bailey and Palermo,
2005).
•
Final Feasibility Study, Lower Fox River and Green Bay, Wisconsin (RETEC Group,
Inc., 2002).
•
Hudson River PCBs Reassessment RI/FS Phase 3 Report: Feasibility Study (TAMS
Consultants, Inc., 2000).
•
Dredging Technology Review Report (TAMS, an Earth Tech Company and Malcolm
Pirnie, Inc., 2004).
•
NJDOT Office of Maritime Resources (NJDOT-OMR), Sediment Decontamination
Technology Demonstration Program Website
(www.state.nj.us/transportation/works/maritime/dresediment.shtm).
3.3
TECHNOLOGY CLASS IDENTIFICATION AND SCREENING
Technology classes presented in this section are grouped by general response action type
as identified in Section 3.1 “Identification of General Response Actions.” Tables 3-1a
through 3-1i describe the technology classes that encompass the means for achieving
these general response actions. For example, removal is a general response action that
may achieve RAOs using the technology class of dredging. Specific process options
were identified within each technology class. For instance, dredging, which is a
technology class, includes such process options as hydraulic dredging, mechanical
dredging, and specialty dredging. Process options applicable to the Area of Focus are
selected based on an understanding of the characteristics of the contaminated media.
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Tables 3-1a through 3-1i also subject the identified process options to a screening based
on the three criteria of implementability, effectiveness, and relative cost. These criteria
are described below.
•
Implementability refers to the technical and administrative feasibility of applying a
particular process option. To determine the implementability of a process option in
the Area of Focus, such factors as obtaining permits for on-site and off-site treatment
and disposal options; the availability of treatment, storage, and disposal facilities; and
the availability of necessary equipment and skilled workers to accomplish the work
are considered.
•
Effectiveness determines the efficacy of a process option, and involves the following
considerations:
─ The ability of the process option to reduce the toxicity, mobility, and/or volume of
contaminant mass through treatment.
─ The degree to which it minimizes residual risks and affords long-term protection.
─ How quickly it achieves protection.
─ The capacity of the process to handle the areas or volumes of contaminated
sediment to be remediated.
─ The degree to which it minimizes short-term impacts to human health and the
environment during the construction and implementation phase.
─ The reliability of the process with respect to the contaminants and conditions in
the Area of Focus.
•
Relative costs for capital as well as operations and maintenance (O&M) were
estimated for each process option for screening purposes. Cost discriminators used
for screening are defined in terms of very high, high, moderate, and low, based on
engineering judgment. For the purposes of this discussion, costs of less than $100/ton
of sediments were considered low, $100 to $500/ton were considered moderate, costs
between $500 and $1,000/ton were considered high, and costs over $1,000/ton were
considered very high. In accordance with the RI/FS guidance (USEPA, 1988), cost
plays a limited role in this preliminary screening of technology classes and process
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options; that is, cost considerations will not be weighed as heavily as the
implementability and effectiveness of process options during screening.
Section 3.3.1 “General Response Action: No Action” through Section 3.3.8 “General
Response Action: Beneficial Use of Dredged Sediments” provide brief descriptions of the
general response actions, technology classes, and process options, and also summarize
the results of the screening process. For additional information, refer to Tables 3-1a
through 3-1i.
3.3.1
General Response Action: No Action
Under the No Action response, no activities involving removal, containment, treatment,
engineering controls, or new institutional controls are implemented; however, a No
Action response may include maintenance of existing institutional controls and/or some
type of environmental monitoring to verify that unacceptable exposures to hazardous
substances do not occur in the future (USEPA, 1988). While sediments in the Area of
Focus pose unacceptable human health and ecological risks (Section 2.6 “Risk Reduction
Resulting from Remediation of Identified Target Areas”), the NCP requires that No
Action be considered as a potential remedial action in a Feasibility Study. It is assumed
that the No Action and MNR responses would be equivalent in terms of predicted future
concentrations and risk reduction (Appendix D “Empirical Mass Balance Model”). The
No Action response will be retained for further evaluation.
3.3.2
General Response Action: Institutional Controls
Institutional controls are potentially applicable and technically implementable as shown
by fish consumption advisories for PCDD/F and PCB currently in place for the Lower
Passaic River. The action is potentially effective for reducing risk to human health by
limiting exposure, but not effective in reducing mobility, toxicity, or volume of
contaminants. Institutional controls such as fish consumption advisories, limitations on
recreational use, restrictions on private sediment disturbance activities, and dredging
moratoriums could be implemented as components of alternatives comprising active
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remedial measures; therefore, the institutional controls response is retained for further
evaluation.
3.3.3
General Response Action: Monitored Natural Recovery
The Contaminated Sediment Remediation Guidance for Hazardous Waste Sites (USEPA,
2005) identifies MNR as a potential remedial alternative for managing contaminated
sediments. This guidance document defines MNR as a remedy for contaminated
sediment that typically uses ongoing, naturally occurring processes to contain, destroy, or
reduce the bioavailability or toxicity of contaminants in sediments.
Changes in surface sediment concentrations over time as determined from dated cores
indicate that natural recovery is occurring to some extent in the Area of Focus; however,
the process is occurring at a rate that is incompatible with its application as an early
action (refer to Appendix D “Empirical Mass Balance Model”). MNR processes are not
effective in reducing mobility, toxicity, or volume of contaminants within a reasonable
time period. MNR, while easily implementable, may not be effective as the sole
component of an early action.
MNR could, however be implemented as a component of alternatives comprising other
active remedial measures. Therefore, MNR has been retained for further consideration as
a component that would follow active remedial measures.
3.3.4 General Response Action: Containment
Sediment containment is usually achieved via the placement of a subaqueous covering or
a cap of clean material over contaminated material that remains in place. Containment
generally can reduce exposure to contaminants more quickly than sediment removal,
because there should be very little contaminant residual on the cap surface (USEPA,
2005). It also requires less infrastructure than sediment removal, in terms of materials
handling, dewatering and treatment (USEPA, 2005). In addition, the need for transport
and disposal of contaminated sediment, which is more costly when ex situ treatment is
required, is negligible for containment compared to removal.
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3.3.4.1
Technology Class: Capping
Engineered Caps. Engineered caps involve the placement of sand or other suitable cover
material over the top of contaminated sediments. Engineered caps are implementable and
many full-scale applications have been documented (refer to SedWebSM website,
www.sediments.org/capsummary.pdf). They are effective in reducing mobility of
contaminants by isolating impacted sediments from the water column, but will not affect
toxicity or volume of contaminants. Their effectiveness may be limited because they
decrease water depth, which may constrain future navigation uses of the river and
potentially increase flooding. Engineered caps have been retained for further evaluation.
Engineered caps may use armor material to add physical stability in erosive settings. The
primary capping material (e.g., sand) is typically covered with stone or another armoring
material. The armor would be designed to be effective in reducing the erosion of the
engineered sand cap; however, armoring along the channel bed increases bed friction and,
consequently, may increase water depths during floods. Armoring may also pose a risk
of damage to ship hulls in navigable reaches. In addition, the design of an armor layer
should take habitat considerations into account (e.g., appropriateness of angular versus
rounded stone). Nevertheless, since armored engineered caps are technically
implementable and effective, they have been retained for further evaluation.
Active Caps. Active caps incorporate materials such as activated carbon, iron filings,
apatite, or other agents into the capping material to enhance adsorption or in-situ
chemical reaction. Active caps eventually lose their sorptive or chemically reactive
treatment capabilities and are typically more difficult to construct than engineered sand
caps. Active capping is an emerging technology that has shown much promise in benchscale, and in limited example pilot-scale applications. It has yet to be applied routinely at
full scale, and therefore would not be suitable for near term action.
Geotextile Caps. Porous geotextile cap layers do not achieve sediment isolation, but
serve to reduce the potential for mixing and displacement of the underlying sediment
with the cap material. Geotextiles allow the sediments to consolidate and gain strength
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under the load of additional cap material. While application of this material over a large
area may be exceptionally challenging for construction, geotextile caps may be
considered during the design phase, perhaps to allow for engineered capping of sediments
in selected areas that do not have adequate strength to support a cap. Geotextiles are
therefore retained.
Clay Caps. Clay aggregate materials (e.g., AquaBlok™) consist of a gravel/rock core
covered by a layer of clay mixed with polymers that expand in water, decreasing the
material’s permeability. Since the use of clay caps over large areas has not been
documented, the effectiveness is unknown. Therefore, clay caps have not been retained
for further evaluation.
3.3.4.2
Technology Class: Structural Containment
Structural containment systems, such as silt traps, create conditions within hydraulic
systems that restrict or reduce flow to such an extent that suspended sediment is removed
from suspension. While structural containment systems are likely to be technically
implementable, a preliminary analysis (Appendix E “Engineering Memoranda: Silt Trap
Evaluation”) indicates that a silt trap would not be effective due to the hydrodynamic and
sediment transport conditions present in the Area of Focus. Hence, structural
containment will not be retained for further evaluation.
3.3.5 General Response Action: In Situ Treatment
In situ treatment of sediments refers to chemical, physical, or biological techniques for
reducing contaminant concentrations and/or contaminant mobility while leaving the
contaminated sediment in place.
3.3.5.1
Technology Class: Immobilization
Immobilization refers to treatment processes such as solidification/stabilization and
encapsulation that physically or chemically reduce the mobility of hazardous constituents
in a contaminated material. In situ immobilization methods typically involve amending
sediments in place with agents such as cement, quicklime, grout, or pozzolanic materials,
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as well as other reagents. These agents are mixed through the zone of contamination
using conventional excavation equipment or specially designed injection apparatus such
as mixing blades attached to vertical augers.
Contaminant Fixation. Immobilization with the goal of contaminant fixation would seek
to physically and/or chemically bind contaminant molecules. Full-scale applications of in
situ solidification/stabilization of sediments are limited and have primarily focused on the
improvement of the geotechnical properties of sediment for construction projects, as
opposed to stabilization with the goal of contaminant mass remediation. The two most
applicable case studies that were found during a literature search are the Minamata Bay
project in Japan, and a pilot study sponsored by NJDOT-OMR in the New York-New
Jersey Harbor. These case studies have been summarized in a memorandum included in
Appendix E “Engineering Memoranda.” Neither of these case studies provided sufficient
data to evaluate the effectiveness of immobilization for the purpose of contaminant
fixation. Therefore, this process option will not be retained for further evaluation.
Erosion Control. Immobilization of surficial sediments for erosion control is potentially
implementable and effective in reducing mobility of contaminated sediments. The
potential effectiveness cannot be evaluated due to the lack of available precedent for this
process. Therefore, this process option will not be retained for further evaluation.
Geotechnical Improvements. Use of immobilization for improvement in sediment
geotechnical properties is fairly common (typically referred to as deep soil mixing). In
addition, improvement of geotechnical properties of sediments in an area to be dredged
may render the sediment more suitable for accurate dredging, and may reduce sediment
resuspension, precluding the need to use containment measures. Immobilization applied
after dredging could result in a more consolidated sediment bed, which would reduce
sediment transport. This option will be retained as a potential ancillary technology to
other process options.
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3.3.5.2
Technology Class: Physical Extractive Treatment
Surfactant-enhanced extraction and solvent extraction were considered as in situ
treatments. These treatments involve the use of an organic solvent or surfactant as an
agent to separate primarily organic contaminants from sediment. For in situ extraction,
the solvent or surfactant would be injected into the contaminated sediment and then
recovered. Treatment or destruction of the contaminant-bearing surfactant or solvent
would be accomplished ex situ. There are no known sediment applications of process
options in this technology class to demonstrate effectiveness. Therefore, physical
extractive process options have been eliminated from further evaluation.
3.3.5.3
Technology Class: Biological Treatment
Biological treatment is a technique in which the physical, chemical, and biological
conditions of a contaminated medium are manipulated to accelerate the natural
biodegradation and mineralization processes. Persistent contaminants, such as those
found in Lower Passaic River sediments (e.g., PCB, PCDD/F), are frequently resistant to
microbial degradation for the following reasons (Renholds, 1998):
•
Poor contaminant bioavailability to microorganisms.
•
Contaminant toxicity to the microorganisms.
•
Preferential feeding of microorganisms on other substrates.
•
Microorganisms’ inability to use a compound as a source of carbon and energy.
•
Unfavorable environmental conditions in sediments for propagation of appropriate
microorganisms.
Since many of the Lower Passaic River contaminants are either not biodegradable
(particularly heavy metals) or are very persistent in the environment (e.g., PCDD/F, PCB,
pesticides), it is not considered feasible to implement biological treatment. Therefore, in
situ biological treatment will not be considered for further evaluation.
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3.3.5.4
Technology Class: Chemical Treatment
In situ chemical treatment would involve the injection of chemical reagents, typically
chemical oxidants or reductants, to chemically react with contaminants to form less toxic
by-products. There are no known sediment applications of these process options to
demonstrate effectiveness and implementability. Therefore, in situ chemical treatment
options will not be retained for further evaluation.
3.3.6
General Response Action: Sediment Removal
Sediment removal is employed in those cases where contaminated sediments are to be
withdrawn for ex situ treatment (refer to Section 3.3.7 “General Response Action: Ex Situ
Treatment”) and/or disposal or beneficial reuse (refer to Sections 3.3.8 “General
Response Action: Beneficial Use of Dredged Sediment” and 3.3.9 “General Response
Action: Disposal of Dredged Sediments”). Sediment removal, if it achieves cleanup
levels for the site, may result in the least uncertainty about long-term effectiveness, since
it can minimize the potential for future exposure and transport of contaminants (USEPA,
2005).
3.3.6.1
Technology Class: Excavation
Excavation of contaminated sediment involves pumping or diverting water from the area
to be excavated, managing continuing inflow, and excavating contaminated sediment
using conventional land-based excavators (such as backhoes). Excavation is considered
both implementable and effective for mass remediation in the Area of Focus. Excavation
technologies have been retained for further evaluation.
3.3.6.2
Technology Class: Dredging
Dredging involves mechanically grabbing, raking, cutting, or hydraulically scouring the
bottom of a waterway to dislodge sediment. Once dislodged, the sediment may be
removed either mechanically with dredge buckets, or hydraulically by pumping.
Mechanical Dredging. Mechanical dredges remove sediments from the bottom of a
waterway using dredge buckets. The mechanical dredges most commonly used in the
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United States for environmental dredging are the clamshell, enclosed bucket, and
articulated mechanical dredges (USEPA, 2005). The Dredging and Decontamination
Pilot Study was conducted in the Lower Passaic River over the period of one week in
December 2005 (Baron et al., 2005). The pilot study provided data related to dredging
accuracy, working time, productivity (Thompson et al., 2006), and resuspension
(Mahmutoglu et al., 2007) for a mechanical clamshell dredge bucket. Mechanical
dredging has been retained for further evaluation.
Hydraulic Dredging. Hydraulic dredges remove and transport dredged materials as a
pumped sediment-water slurry. Implementation of this process option would require that
significant infrastructure be constructed to convey, process, and dewater dredged slurry,
and this infrastructure would likely require significant acreage near the site of dredging.
In addition, the presence of debris could hinder the productivity of hydraulic dredges.
Despite these challenges, given the soft, unconsolidated nature of the Area of Focus
sediment, hydraulic dredging is a potentially effective means of sediment removal.
Hydraulic dredging has been retained for further evaluation.
Specialty Dredges. Specialty dredges have been designed to address project-specific
issues, such as accessibility and resuspension. Although specialty dredging techniques
exist that may be technically implementable, conventional dredges are generally more
effective with regard to productivity and working conditions, and advances in
environmental dredging have effected improvements in precision sufficient for most
situations. Specialty dredges will not be evaluated further in this FFS, but may be
considered for managing specific situations that may become evident during a design
phase.
3.3.7
General Response Action: Ex Situ Treatment
Ex situ treatment of sediments refers to chemical, physical, or biological techniques for
reducing contaminant concentrations and/or contaminant mobility in dredged material.
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3.3.7.1
Technology Class: Immobilization
Immobilization refers to treatment processes that physically or chemically reduce the
mobility of contaminant constituents in dredged material. Ex situ immobilization
methods involve mixing setting agents such as cement, quicklime, grout, pozzolanic
materials, and/or reagents with sediments in a treatment unit. Sediments generally
require some pre-processing, such as screening of oversized material, prior to
solidification/stabilization. The effectiveness of solidification/stabilization technologies
is variable depending on the characteristics of the contaminated sediment and the
particular additives used. Solidification/stabilization of sediment is commonly required
prior to its use in a beneficial application, such as for construction fill. A knowledge base
for this technology exists within the Port of New York and New Jersey region using
navigationally dredged material; project examples include the Orion of Elizabeth New
Jersey (OENJ) shopping mall construction, OENJ Bayonne golf course, and EnCap Gold
Holdings, LLC Golf Holdings golf course in Lyndhurst, New Jersey.
Since ex-situ immobilization may effectively fix or bind contaminants in dredged
material, and because such immobilized dredged material has potential beneficial uses
(including sanitary landfill cover, construction fill, and mined land restoration), this
technology will be retained for further consideration.
3.3.7.2
Technology Class: Physical/Chemical Extractive Treatment
Solvent Extraction. Solvent extraction involves the use of an organic solvent as an agent
to separate primarily organic contaminants from dredged material. Using such a process
alone would likely be insufficient to treat the dredged material given the variety of
contaminants. Therefore, solvent extraction will not be further evaluated as a process
option, but “Surfactant Enhanced Recovery” may be considered as a step in a treatment
train for sediment washing (see below).
Sediment Washing. Sediment washing is a water-based volume reduction process similar
to the soil washing techniques used in the mining industry. During this process
contaminants are extracted and concentrated into a small residual portion of the original
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volume using physical and chemical means (USEPA, 2005). Since this process was
shown to be implementable and potentially effective by BioGenesis™ Enterprises, Inc.
for dredged material from Newark Bay and the Lower Passaic River, sediment washing is
retained for further evaluation. Refer to Appendix H “Dredged Material Management
Assessments” for more information.
3.3.7.3
Technology Class: Biological Treatment
Biological treatment is a technique in which the physical, chemical, and biological
conditions of a contaminated medium are manipulated to accelerate the natural
biodegradation and mineralization processes. Since many of the contaminants present in
the Area of Focus are either not biodegradable (e.g., heavy metals) or are resistant to
biological degradation (e.g., PCDD/F, Total PCB, pesticides), biological treatment is not
considered to be feasible. Thus, ex situ biological treatment will not be considered for
further evaluation.
3.3.7.4
Technology Class: Thermal Treatment
Thermal Desorption. Thermal desorption is a treatment technology which is designed to
remove contaminants from solid media by volatilizing them with heat at belowcombustion temperatures [typically 200 degrees Fahrenheit (°F) to 1,000°F] in a primary
chamber. The desorbed contaminants are then treated in a secondary unit to control air
emissions. Many thermal desorption units are smaller, portable systems that may be
inadequate for larger sized dredging projects. The efficiency of thermal desorption
decreases with increased soil moisture content. Clay and silty soils and high humic
content soils increase reaction time as a result of binding of contaminants
(www.frtr.gov/matrix2/section4/4-26.html). In addition, since thermal desorption does
not treat metals, the treated residue will need to be further processed to immobilize the
metals. Since the sediments from the Area of Focus are mostly fine-grained and contain
high concentrations of heavy metals, thermal desorption will not be retained for further
evaluation.
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Thermal Destruction. Thermal destruction is a controlled process that uses high
temperatures (typically between 1,400°F and 2,200°F) to volatilize and combust organic
chemicals. Thermal destruction has been demonstrated to be very effective in destroying
organic contaminants such as PCDD/F, PCB, and PAH. The process is potentially
implementable as there are several facilities in the United States (primarily in Texas and
other western states) and Canada that are permitted to accept such waste materials.
The Cement-Lock® process described in Table 3-1g (attached) has been demonstrated to
be effective in treating contaminated dredged sediments and in producing a beneficial use
product. This beneficial use product is a construction-grade cement in which the nonvolatile metals originally present in the sediment are bound via an ionic replacement
mechanism (refer to Appendix H “Dredged Material Management Assessments”).
Volatile heavy metals – such as mercury – are removed from the flue gas as it passes
through a bed of activated carbon pellets. Thermal destruction is retained for further
evaluation because it is one of the only technologies proven as effective in treating the
organic COPCs and COPECs (i.e., PCDD/F, PCB, and PAH) detected in the sediment of
the Area of Focus.
Vitrification. Vitrification is a process in which higher temperatures (2,500°F to
3,000°F) are used to destroy organic chemicals by melting the contaminated dredged
material to form a glass aggregate product. Vitrification has been demonstrated to be
very effective in destroying organic contaminants such as PCDD/F, PCB, and PAH in
dredged material. The vitrification technology has been commercialized by Minergy
Corporation, which operates facilities in Neenah and Winneconne, Wisconsin, and is
constructing another facility in Zion, Illinois (primarily for biosolids treatment).
Currently no full-scale operating facility exists with sufficient capacity to accept large
volumes of dredged material from the Area of Focus. Therefore, vitrification is
considered for further evaluation, but construction of a new facility would potentially be
required.
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3.3.8
General Response Action: Beneficial Use of Dredged Sediments
Sanitary Landfill Cover. Sanitary landfills accept dredged material on a case-by-case
basis. Given the restrictions placed on land disposal of PCDD/F-containing materials
(refer to Appendix H “Dredged Material Management Assessments”), only a small
portion of dredged material from the Area of Focus would likely be suitable for landfill
cover. Nevertheless, because of the potential beneficial use of dredged material as
compared to disposal options such as landfilling as a waste, use as sanitary landfill cover
is retained for further evaluation.
Construction Fill. This beneficial use option may be suitable for dredged material with
low concentrations of contaminants (especially if the dredged material is subjected to a
relatively low-cost treatment such as solidification/stabilization) or for more
contaminated dredged material that has been more aggressively treated. One example of
such a project is the EnCap Golf Holdings, LLC redevelopment project in the
Meadowlands area in New Jersey. Because of the potential beneficial use of dredged
material as compared to disposal options such as landfilling as a waste, use as
construction fill is retained for further evaluation.
Mined Lands Restoration. Dredged material can be beneficially used in the restoration of
abandoned surface mined lands and to restore, protect, and enhance lands damaged by
mining. The goal is to successfully use the dredged material to stabilize and re-vegetate
the damaged lands, reduce acid mine drainage and restore the local ecosystem.
Abandoned mine reclamation is an attractive beneficial use option because of the
potential for placement of very large volumes of dredged material. It is estimated that the
state of Pennsylvania’s mine fill requirement is in excess of 10 billion cubic yards (New
York/New Jersey Clean Ocean and Shore Trust and PaDEP, 2006). Determination of
whether this option is implementable using dredged material from the Area of Focus
would require consideration of whether contaminant concentrations meet NJDEP and
Pennsylvania Department of Environmental Protection (PaDEP) requirements,
availability of nearby sources of admixture, accessibility of the sediment processing site
to rail, and acceptance by the local community. Many mined sites should have rail access
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so that transport of sediment can be achieved via rail car, which is more efficient than via
truck. Given the effectiveness observed during the successful reclamation project at the
Bark Camp Mine Reclamation Experimental Facility in central Pennsylvania [refer to
Table 3-1h (attached)], and the potential for the acceptance of large quantities of
sediment (e.g., Springfield Pit), this option will be retained for further evaluation.
3.3.9 General Response Action: Disposal of Dredged Sediments
Options involving sediment removal from the Lower Passaic River will require some
means of final placement after dewatering and/or treatment via ex situ techniques
described above. Placement options considered include land disposal, aquatic disposal,
and beneficial use (refer to Section 3.3.8 “General Response Action: Beneficial Use of
Dredged Sediments”).
3.3.9.1
Technology Class: Land Disposal
Land disposal of contaminated sediments may be accomplished in landfills or in upland
CDFs. Upland CDFs may accommodate mechanically or hydraulically dredged
sediments and can be designed and operated to accomplish both dewatering and
encapsulation.
The LDR under the Hazardous and Solid Waste Amendments (HSWA) to RCRA must be
considered for land disposal options. The LDR program identifies treatment standards to
manage restricted wastes destined for land disposal.
Off-Site Landfill. Landfill acceptance of dredged material is determined on a case-bycase basis because permit requirements are facility-specific. Off-site landfill disposal in a
local non-hazardous landfill may be effective and implementable for less-contaminated,
untreated dredged material from the Area of Focus, or for more contaminated dredged
material that has been treated to an acceptable degree. Off-site landfill disposal will be
retained for further evaluation.
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Upland CDFs. An upland CDF is an engineered structure enclosed by dikes, berms, or
walls and specifically designed to contain dredged material. It may be considered as a
final disposal site or as a temporary storage location prior to dredged material treatment.
The main challenge to implementability of this process option is identifying and
obtaining approvals for a site that is proximal and of sufficient size to accommodate the
potentially large volumes of more highly contaminated dredged material to be generated.
A summary of an upland CDF siting study performed by NJDEP is included in Appendix
H “Dredged Material Management Assessments”. Upland CDFs are retained for further
evaluation.
3.3.9.2
Technology Class: Aquatic Disposal
If dredged material is removed but replaced in water within the Area of Contamination,
which for this FFS includes the Lower Passaic River, Newark Bay, and areal extent of
contamination, LDRs are not triggered.
CAD. Disposal of dredged material in open water CAD cells has been practiced for
many years, primarily for navigational dredging projects. CAD involves subaqueous
covering or capping of dredged material, whether simply placed on the bottom or
deposited in depressions or excavated pits. Even for dredged material derived from
navigation projects, CAD cells have been viewed unfavorably by the regulatory and
environmental communities. Compared to nearshore CDFs, there is not nearly the
potential for control of effluent, precise placement of the material into the CAD unit, nor
the ability to minimize sediment resuspension. The presence of the Newark Bay CDF
near the Elizabeth Channel demonstrates that this option is implementable 5, however
recent usage has been limited to emergency projects or projects with a demonstrated
hardship (i.e., other cost-feasible options are not available). Furthermore, disposal in
CAD cells would essentially eliminate the potential for temporary storage because of the
impacts associated with placement and redredging for treatment. Therefore, CAD cells
will not be retained for further evaluation.
5
Note that although it is referred to as a CDF, the Newark Bay facility is technically a CAD as defined in
this document.
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In-water CDF. A CDF may be constructed as an in-water site (i.e., a containment island).
An in-water CDF can be constructed with dikes or other containment structures to
contain the contaminated dredged material, isolating it from the surrounding
environment. Challenges to implementability include waterway impacts, such as
disruption of circulation patterns, and the difficulty associated with construction and
operation of an in-water CDF using marine-based equipment, especially if the CDF is
used for dewatering and storage prior to treatment. In addition, in-water CDFs are
difficult to site and present obstacles to obtaining regulatory approvals due to the required
mitigation for impacts to benthic and aquatic habitat, Previous attempts to site in-water
CDFs in the Port region have not succeeded, at least partially due to aesthetic concerns.
For these reasons, in-water CDFs are not retained for further evaluation.
Nearshore CDF. A CDF may also be constructed as a nearshore site (i.e., in water with
one or more sides adjacent to land). In some cases, a nearshore CDF can be integrated
with site reuse plans to both reduce environmental risk and simultaneously foster
redevelopment in urban areas and brownfields sites (USEPA, 2005). Based on a
preliminary inspection of land use and waterway characteristics, several potential sites for
nearshore CDFs have been identified. These sites are amenable to the development of a
CDF of sufficient size to accommodate the material to be removed from the Lower
Passaic River as a consequence of any alternative and could also provide temporary
storage for sediment to be treated at a later date. Nearshore CDFs are retained for further
evaluation.
3.4
ANCILLARY TECHNOLOGIES
Additional technologies and process options that are ancillary to those retained process
options presented in Section 3.3 “Technology Class Identification and Screening” may be
incorporated in any remedial alternative implemented in the Area of Focus. They are
described here in relation to their potential applicability to some of the primary
technologies that are evaluated.
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3.4.1
Sediment Dispersion Controls
Water-borne transport of resuspended contaminated sediment released during dredging
can often be reduced by using physical barriers around the dredging operation area. Two
of the more common approaches include silt curtains and sheet-pile walls.
Silt curtains are floating barriers designed to control the dispersion of sediment in a body
of water. They are made of impervious flexible materials such as polyester-reinforced
thermoplastic (vinyl) and coated nylon. The effectiveness of silt curtains and screens is
primarily determined by the hydrodynamic conditions at the site. Conditions that may
reduce the effectiveness of these and other types of barriers include the following:
significant currents, high winds, changing water levels and current direction (i.e., tidal
fluctuation), excessive wave height, and drifting ice and debris (USEPA, 2005). Silt
curtains are generally more effective in relatively shallow, undisturbed water. As water
depth increases and turbulence caused by currents and waves increases, it becomes
difficult to isolate the dredging operation effectively from the ambient water. Under ideal
conditions, turbidity levels in the water column outside the curtain can be as much as 80
to 90 percent lower than those levels inside or upstream of the curtain (Francingues and
Palermo, 2005).
Sheet-piling consists of a series of panels with interlocking connections driven into the
ground with impact or vibratory hammers to form an impermeable barrier. Sheets can be
made from a variety of materials such as steel, vinyl, plastic, wood, recast concrete, and
fiberglass. Sheet-pile containment structures are more likely to provide reliable
containment of resuspended sediment than silt curtains, although at significantly higher
cost and with different technological limitations. Sheets must be properly imbedded into
the subsurface to ensure that the sheet pile structure will withstand the hydraulic forces
(e.g., waves and currents). Sheet-pile containment may increase the potential for scour
around the outside of the containment area. Also, resuspension may occur during
placement and removal of these structures. In addition, use of sheet-piling may
significantly change the carrying capacity of a stream or river and make it temporarily
more susceptible to flooding (USEPA, 2005).
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An alternative to sheet-piling is the in situ solidification/stabilization of sediments in an
area to be dredged. The improvement of geotechnical properties of sediments in an area
to be dredged may render the sediment more suitable for accurate dredging, and may also
result in a stronger sediment bed which may not require sheet-pile to maintain sidewall
stability during dredging operations. If successful, solidification/stabilization might have
the benefit of reducing resuspension, as well as improving the handling characteristics of
the sediment for transportation and disposal or treatment.
3.4.2 Dewatering
Dewatering involves reduction in the moisture content of dredged material to produce a
material more amenable to handling with general construction equipment and that meets
landfill disposal or treatment plant criteria (e.g., paint filter test or percent moisture for
thermal treatment). Selection of an appropriate dewatering technology depends on the
physical characteristics of the material being dredged, the dredging method, and the
target moisture content of the dewatered material.
The ARCS Remediation Guidance Document (USEPA, 1994) has classified dewatering
technologies into three general types: passive dewatering, mechanical dewatering, and
active evaporative technologies. These dewatering methods, as well as desiccation via
amendment, are summarized in Table 3-2.
Table 3-2: Dewatering Methods
Category
Description
Passive
Relies on settling,
surface drainage,
consolidation, and
evaporation to
remove water
Mechanical
Active
evaporative
Active
amendment
Input of energy to
squeeze, press or
draw water from
sediments
Artificial energy
sources to heat
sediments and
remove moisture
Addition of
pozzolanic material
Methods
Settling basins with
underdrains; tanks,
lagoons, surface
impoundments
Advantages
Low cost
Belt filter presses, plate High processing
filter presses,
rates, less time and
hydrocyclones,
space required
centrifuges
Flash dryers, rotary
Can achieve the
dryers, modified
highest solids
multiple hearth furnaces content (up to 90
percent)
Portland Cement,
Low cost, easily
quicklime, grout, ash
implementable
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Disadvantages
Large amounts of time
and space required; not
feasible for large
dewatering projects;
potential for air
emissions
High operations and
maintenance costs
High energy costs;
capture and treatment of
air emissions
Increase in volume
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Dewatering of significant amounts of dredged material requires a land-based staging area
in close proximity to the dredging site. The area should be accessible to barges, large
equipment, and trucks, and should incorporate security measures such as signage,
fencing, and/or guard patrol to limit access by unauthorized personnel. Larger
dewatering projects, even with mechanical dewatering systems, require large amounts of
space. Plans for a dewatering facility should include details such as berms, runoff
collection systems, and turbidity controls. Optimal dewatering system operating
characteristics include: small footprint, high production rates, and low cost. The design
of a dewatering system should be based on consolidation tests performed on material
from the site to be dredged.
3.4.3
Wastewater Treatment
The purpose of wastewater treatment is to prevent adverse impacts of a dewatering
effluent discharge on the receiving water body, which may be a permitted discharge to
the Lower Passaic River or Newark Bay, a POTW, or an industrial wastewater facility.
Mechanically dredged material typically has a solids content of approximately 25 to 50
percent by weight, while hydraulically dredged material is in the form of a slurry with a
solids content typically in the range of 2 to 10 percent (the higher percentage generally
applies to bank or surface material). Dewatering these dredged materials requires
management of the contaminated dewatering stream to meet effluent water quality
criteria for discharge to the receiving system. Therefore, a water treatment system would
typically be included as part of the treatment train for the dewatering process. However,
water quality may also be adversely impacted in and around dredging operations through
resuspension and dispersion of contaminated sediments. The following sections briefly
describe potential treatment trains to handle water from mechanically and hydraulically
dredged material.
3.4.3.1
Mechanical Dredging Water Treatment.
Free water from mechanical dredging primarily accumulates within transfer barges or at
the stockpile facility. Dredged material transfer barges may be left idle before off-
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loading to allow for collection of free water at the surface of the load by dredged material
consolidation. The free water can then be decanted and pumped ashore to a water
treatment system, if necessary, prior to unloading the dredged material. An onshore
water treatment system may consist of tanks for sedimentation, coagulation followed by
secondary settling, and filtration or adsorption using sand or granular activated carbon.
3.4.3.2
Hydraulic Dredging Water Treatment.
Hydraulic dredging results in a large volume of sediment-water slurry to be managed.
Passive dewatering is commonly applied for hydraulically dredged material. If suitable
upland areas are not identified, other dewatering options would include passive
dewatering in a nearshore CDF or by mechanical methods. Mechanical systems typically
utilize screens and centrifuges for solids removal, in some cases aided by chemical
coagulants and short-term gravity separation. Large tanks would be required to allow the
addition of a coagulating agent to assist in secondary settling. As described above,
depending on effluent criteria, the water would then be filtered and potentially passed
through granular activated carbon to remove organic contaminants.
3.4.4
Transportation
A means of transportation will be required for any remedial alternative that involves
removal of contaminated sediments from the Area of Focus. The transportation method
included in each remedial alternative will be based upon the compatibility of that
transportation method to the other process options. The most likely transportation
methods are truck, rail, and barge. These are briefly discussed below. Appendix H
“Dredged Material Management Assessments” includes a memorandum summarizing
waterborne, rail, and road access associated with potential sediment processing or
placement sites.
3.4.4.1
Truck
Truck transportation includes the transport of dewatered dredged material over public
roadways using dump trucks, roll-off boxes, or trailers. This form of transportation is the
most flexible, but can be very costly over long distances. Truck transport also has the
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greatest potential for impact on local streets and traffic, depending on the location of the
processing facility with respect to major highways.
3.4.4.2
Rail
Rail transportation includes the transport of dewatered dredged material via railroad
tracks using gondolas or containers. Rail transport is desirable where sediment is shipped
over long distances, for instance, to out-of-state treatment or disposal facilities. Because
rail transport requires coordination between multiple owners, and because many
operators are unwilling to provide detailed information prior to entering actual
negotiations, it is difficult to obtain accurate cost estimates. Rail transport may require
the construction of a rail spur from a sediment handling facility to a commercial track.
3.4.4.3
Barge
Barge transportation includes the transport of dewatered dredged material via existing
navigable waterways using barges. Barge transport would likely be used for short
distances, such as from the dredging location to the dredged material handling facility. In
addition, barge transport may be considered for longer distances if dredged material is
hauled to out-of-state treatment or disposal locations that have the ability to accept bargeloaded dredged material.
3.4.5
Restoration
The implementation of a remedial alternative in the Area of Focus would impact existing
habitat conditions. As part of the reconstruction of the remediated area, substrate would
be placed that would be suitable for future activities relating to habitat construction.
Certain types of restoration would likely be feasible to integrate with a remedial action,
including riparian fringe restoration, mudflat reconstruction, and benthic habitat creation.
In addition, biostabilization techniques could be considered as an alternative erosion
protection measure and could have the added benefit of providing submerged aquatic or
tidal emergent habitat.
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The Study will also identify potential restoration opportunities (wetland creation,
enhancement, etc.) that could be implemented following remediation beyond
reconstruction to original grade. These activities are conducted as part of the WRDA
function of the joint program. At present, there are efforts planned by the USACE to
begin development of conceptual restoration plans as a companion to early action
alternatives (refer to www.ourpassaic.org for additional information regarding
restoration).
3.5
IDENTIFICATION OF RETAINED PROCESS OPTIONS
In addition to the No Action response, the following process options have been retained
for further evaluation:
•
Institutional controls, including, but not limited to, fish consumption advisories and
dredging restrictions in shoal areas.
•
Monitored natural recovery processes, including but not limited to burial,
sedimentation, degradation, sorption, and oxidation.
•
Containment via engineered caps and geotextiles.
•
Sediment removal via excavation, mechanical dredging, and/or hydraulic dredging.
•
In situ immobilization for the purposes of geotechnical improvements and
resuspension control.
•
Ex situ treatment via immobilization, sediment washing, vitrification, or thermal
destruction.
•
Beneficial uses including sanitary landfill cover, construction fill, brownfields
remediation material, and mined lands reclamation.
•
Disposal in an off-site landfill, upland CDF, or nearshore CDF unit.
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4.0
DEVELOPMENT OF REMEDIAL ACTION ALTERNATIVES
The purpose of this section is to develop a set of remedial alternatives for remediation of
contaminated sediment in the Area of Focus. The alternative development criteria
described in Section 4.1 “Alternative Development Criteria” were considered when
assembling remedial alternatives using the representative process options (described in
Section 4.2 “Selection of Representative Process Options”). Conceptual designs for the
active alternatives are presented in Figures 4-1 through 4-6.
The alternatives developed and screened in this FFS are conceptual. All characteristics of
these alternatives (e.g., sediment removal rates and depths, dredged material volumes,
dredged material treatment facility throughputs, and bulk sediment chemical
constituency) should be considered to be approximate for the purposes of a feasibility
comparison only. Specific details would need to be finalized during a remedial design.
4.1
ALTERNATIVE DEVELOPMENT CRITERIA
The following sections present criteria that were considered during the development of
remedial alternatives to treat contaminated sediment in the Area of Focus.
4.1.1 ARARs
Alternative development must conform to the requirements of CERCLA Section 121(d),
which requires that Superfund remedial actions comply with federal and state ARARs, or
justify a waiver. Refer to Section 2.0 “Development of Remedial Action Objectives and
Selection of Target Areas” for more information regarding ARARs.
4.1.2
Statutory Preferences
CERCLA Section 121(b) identifies the following statutory preferences that must be
considered in the development and evaluation of remedial alternatives:
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•
Remedial actions that involve treatment that permanently and significantly reduces
the volume, toxicity, or mobility of the hazardous substances through treatment are
preferred over remedial actions not involving such treatment.
•
Off-site transport and disposal of hazardous substances or contaminated materials
without treatment is considered the least favorable remedial alternative when
practicable treatment technologies are available.
•
Remedial actions using permanent solutions, alternative treatment technologies, or
resource recovery technologies that, in whole or in part, will result in a permanent and
significant decrease in toxicity, mobility, or volume of a hazardous substance are
preferred.
Remedial alternatives for the FFS were developed in consideration of these statutory
preferences. They include source control remedies that seek to prevent or minimize the
migration of hazardous contaminants. They have also been designed to reconstruct and
monitor substrate for benthic and fish habitat in areas where short-term impacts to such
habitat due to containment or removal actions are unavoidable to meet the RAOs.
4.1.3
Navigation Requirements
The Lower Passaic River contains a federally-authorized navigation channel (refer to
Appendix F “Navigation Studies”). In RM0 to RM7, it is 300 feet wide and ranges in
depth from 30 feet mean low water (MLW) to 16 feet MLW. In RM7 to RM8, it is 200
feet wide and 16 feet (MLW) deep. The most recent dredging in the river occurred in
1983, when approximately 540,000 cubic yards of sediment were removed from the
lower portion of the river near Newark (Ianuzzi, et al., 2002). Since that time, sediment
deposition in the navigation channel has reduced the available draft to less than its
authorized depth.
According to Land Use in the CERCLA Remedy Selection Process (USEPA, 1995),
remedial alternatives developed during the RI/FS should reflect reasonably anticipated
future land use(s). On the shores of the Lower Passaic River, land use and navigation use
(and thus navigation channel depth) are very often linked. In order to evaluate the
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channel dimensions necessary to accommodate current navigation usage, USACE-New
York District conducted a survey of commercial stakeholders along the Lower Passaic
River. In order to evaluate the channel dimensions necessary to accommodate reasonably
anticipated future usage of the river, the State of New Jersey conducted surveys of
municipalities and other local organizations along the Lower Passaic River. Results of
their evaluations are presented in Appendix F “Navigation Studies”. Several active
remedial alternatives were developed in consideration of these navigation requirements,
which are described below.
4.1.3.1
Current Federally Authorized and Constructed Navigational Channel
Depths
The current federally authorized channel depths of the commercially navigable portion of
the Lower Passaic River are as follows:
•
RM0 to RM2.5: The federally authorized and constructed channel depth is 30 feet
relative to MLW. A bridge abutment at RM1.2 limits channel width to 145 feet. The
Point-No-Point Swing Bridge at RM2.5 limits channel width to 103 feet and limits
vertical clearance to 16 feet at high water.
•
RM2.5 to RM4.6: The federally authorized and constructed channel depth is 20 feet
MLW.
•
RM4.6 to RM7.1: The federally authorized channel depth is 20 feet MLW; however,
the channel was only constructed to 16 feet MLW.
•
RM7.1 to RM8.1: The federally authorized and constructed channel depth is 16 feet
MLW.
•
RM8.1 to RM15.4: The federally authorized and constructed channel depth is 10 feet
MLW.
As stated previously in Section 1.3.2 “CSM of the Lower Passaic River,” since the 1940s
there has been little maintenance dredging above RM2. Consequently, the channel has
extensively filled back in, particularly between RM2 and RM8.
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4.1.3.2
Navigational Channel Dimensions to Accommodate Current Usage
The USACE conducted an analysis of waterborne commerce conducted between 1980
and 2004 in the Lower Passaic River. The analysis concluded that over 90 percent of
cargo transported along the river is carried in vessels loaded to less than 13 feet draft,
with the exception of 13 records of vessels having 26-foot drafts in 2004. Because the
bulk of these shipments occurred between RM0 and RM1.2 where the authorized and
constructed depth is 30 feet, the analysis concluded that commercial navigation on the
Lower Passaic River is most likely currently constrained by width rather than by depth.
The width constraint is due to requirements associated with safe navigation: channel
width should be at least five times the beam of the vessel for two-way traffic, and at least
three times the beam of the vessel for one-way traffic, with beam defined as the width of
a vessel at its widest point, usually midship.
Based on USACE data, the dimensions of a navigation channel within the lower eight
miles of the Lower Passaic River that would accommodate the current usage are as
follows:
•
RM0 to RM1.2: The future authorized depth should be maintained at 30 feet MLW
based on United States Waterborne Commerce data that indicate 13 barges requiring
26-foot drafts were recorded in 2004.
•
RM1.2 to RM2.5: The future authorized depth should be a minimum of 16 feet MLW
based on the 5.5-foot tidal range in the lower 2.5 miles of the Passaic River.
Requiring shipments to coincide with high tide in order to maintain safe passage will
impose operational limitations to the timing of commerce if the constructed depth
falls below this authorized depth.
4.1.3.3
Navigational Channel Depths to Accommodate “Future Usage”
Channel depths to accommodate future usage were considered by the State of New Jersey
and were based on future use surveys for municipalities, an evaluation of market and land
use scenarios for the Passaic River Region, statewide economic and revitalization
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programs, as well as the USACE Navigation Analysis. The State’s future usage
recommendations are as follows:
•
RM0 to RM1.2: The future authorized depth should be maintained at 30 feet based
on United States Waterborne Commerce data that indicate a potential for increased
use by vessels requiring 26-foot drafts.
•
RM1.2 to RM2.5: The depth should not be less than 16 feet based on future industrial
users, brownfields and portfields sites. Additional discussions need to take place
among the State and the City of Newark and Kearny for this upper reach.
•
RM2.5 to RM3.6: A minimum of 16 feet depth is required for this segment in order to
preserve the potential for future navigational use and economic revitalization of the
region.
•
RM3.6 to RM4.6: The future authorized depth can be reduced to 10 feet, which will
accommodate future ferry/water taxi operations planned for waterfront redevelopment
in the City of Newark.
•
RM4.6 to RM8: The future authorized depth can be reduced to 10 feet to support
recreational vessels (with typical drafts of less than 3 feet) and water taxis.
4.1.3.4
Other Navigation Issues
In addition to navigation channel configuration, construction of berth areas is another
component of navigation on the Lower Passaic River. Berth areas that have been
historically dredged may contain thick silt deposits associated with contaminant
inventory. Currently, locations of berth areas are unknown. Berth areas are likely to be
addressed under local or state programs, although restrictions on dredging in capped
areas would need to be imposed to maintain the integrity of the remedy.
4.2
SELECTION OF REPRESENTATIVE PROCESS OPTIONS
In addition to the No Action Response, seven general response actions were retained after
screening remedial technologies in Section 3.0 “Identification and Screening of General
Response Actions, Remedial Technology Classes, and Process Options.” These general
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response actions, and the process options chosen to represent them for the purposes of the
conceptual design and feasibility evaluations presented in this document, are discussed
below.
It is important to note that the selection of representative process options presented below
is for the purposes of this feasibility evaluation only, and that other process options may
be identified and selected during a design phase.
•
No Action: The No Action response does not include any containment, removal,
disposal, or treatment of contaminated sediment. It does, however, assume the
continuation of current institutional controls such as fish consumption advisories. It
also includes the five-year remedy reviews required under CERCLA Section 121(c).
•
Institutional Controls: It is likely that implementation of any remedial action would
require the maintenance of existing institutional controls (e.g., fish consumption
advisories). Additional institutional controls such as restrictions or special conditions
(e.g., to protect cap integrity) imposed on private sediment disturbance activities
could also be implemented as components of alternatives comprising active remedial
measures.
•
Monitored Natural Recovery: As discussed in Section 3.3.3 “General Response
Action: Monitored Natural Recovery,” MNR may not be effective as the sole
component of an early action, but could be implemented as a component of
alternatives comprising other active remedial measures.
•
Sediment Removal: Three process options for sediment removal were retained in
Section 3.0 “Identification and Screening of General Response Actions, Remedial
Technology Classes, and Process Options” as being potentially implementable and
effective for the Lower Passaic River: excavation, hydraulic dredging, and
mechanical dredging. For the purposes of describing and estimating costs of remedial
alternatives involving sediment removal, mechanical dredging has been selected as
the representative process option. Mechanical dredging has been selected due to (a)
the availability of site specific data regarding implementation, which was obtained
during the Dredging and Decontamination Pilot Study (Thompson et al., 2006), (b)
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the additional challenges to implementability associated with the infrastructure needs
for hydraulic dredging, and (c) the presence of extensive debris, which could present
challenges to the effectiveness of hydraulic dredging.
•
In Situ Treatment: In situ immobilization for improvement in sediment geotechnical
properties was retained as a potential ancillary technology to other process options.
In situ immobilization was not selected as a representative option in the development
of remedial alternatives and costs for this feasibility evaluation; however, its use may
be incorporated during a future design phase.
•
Sediment Containment: As a result of the technology screening presented in Section
3.0 “Identification and Screening of General Response Action, Remedial Technology
Classes, and Process Options,” two process options for sediment containment were
retained: engineered caps and geotextiles. Due to the large area being considered for
remediation and the lack of precedent for implementation of a geotextile over such a
large area, engineered caps have been selected as the representative process option for
alternatives involving sediment containment.
•
Ex situ Treatment: The ex situ treatment process options carried forward from Section
3.0 “Identification and Screening of General Response Action, Remedial Technology
Classes, and Process Options” are immobilization, sediment washing, and thermal
treatment via thermal destruction or vitrification. Each of these technologies could be
applied to treat sediment from the Area of Focus; however, the treatment efficiencies
vary depending on several factors, one of the most important of which is sediment
contaminant concentration. The effectiveness of immobilization treatment is highly
dependent on the initial sediment contaminant concentrations, and so it would be
more suitable for sediment with lower contaminant concentrations. The treatment
efficiency of sediment washing is a function of initial sediment contaminant
concentrations, but also the class of contaminants that are present. Based on a recent
pilot study (refer to Appendix H “Dredged Material Management Assessments”),
certain classes of compounds are treated at higher efficiencies [e.g., volatile organic
compounds (VOCs)] and others are treated at a lower efficiency (e.g., PAH).
Thermal treatment generally provides the highest treatment efficiencies with the least
sensitivity to initial sediment contaminant concentrations.
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It is anticipated that several logistical issues would be encountered in attempting to
segregate sediments from the Area of Focus based on contaminant concentrations.
This is primarily because of the spatial heterogeneity in the contaminant distribution
(refer to Appendix A “Conceptual Site Model”). Given the anticipated challenges for
sediment segregation, the selected ex situ treatment process(es) must be capable of
treating the highest concentrations of contaminants with the greatest efficiency. In
addition, statutory preference is accorded to treatment technologies that permanently
treat the hazardous substances through destruction of contaminants, reduction of total
mass of contaminants, irreversible reduction in contaminant mobility, or reduction of
total volume of contaminated media (USEPA, 1988). The thermal treatment process
options, thermal destruction and vitrification, meet the criteria of permanently treating
the sediments while achieving the highest treatment efficiencies. For purposes of
developing the remedial alternatives and cost estimates, thermal destruction was
selected as the representative ex situ treatment process option. Specifically, the
Cement-Lock® process was selected since it produces a beneficial use product that
offsets a significant portion of the treatment costs, and because it has been shown to
achieve a high treatment efficiency for Passaic River sediments based on the results
of a pilot demonstration in which 16.5 tons of Passaic River sediment were treated
(refer to Appendix H “Dredged Material Management Assessments”). Additional
treatment will be conducted and results evaluated in summer 2007.
•
Beneficial Use of Dredged Sediments: Beneficial use options that have been
considered include landfill cover, construction fill, brownfields remediation, and
mined lands restoration. These options would entail immobilization treatment of
dredged sediments to solidify, stabilize, and/or encapsulate contaminants. Given the
complexities associated with segregating dredged material, and the uncertainties
regarding the effectiveness of immobilization treatment for highly contaminated
sediments, these beneficial use options have not been selected for use in remedial
alternative development. It should be noted, however, that the representative ex situ
treatment option (thermal destruction) results in a beneficial use end product. In
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addition, the representative disposal option of nearshore CDFs (see below) may
provide a beneficial use through reclamation of nearshore land.
•
Disposal of Dredged Sediments: The disposal process options that were carried
forward from Section 3.0 “Identification and Screening of General Response Action,
Remedial Technology Classes, and Process Options” include off-site landfills, upland
CDFs, and nearshore CDFs. Upland and nearshore CDFs offer the advantages of
being used either as final disposal sites or as temporary rehandling sites for storage or
processing prior to sediment treatment. Nearshore CDFs have the added benefit of
being in water within the Area of Contamination (which is the Lower Passaic River,
Newark Bay, and areal extent of contamination), so that LDRs would not be
triggered. In addition, nearshore CDFs are easier to integrate with dredging (e.g., it
would be easier to transport and to offload dredged material to a nearshore CDF as
opposed to an upland CDF). Therefore, nearshore CDFs have been selected as the
representative process option for disposal of dredged sediments.
4.3
DEVELOPMENT OF REMEDIAL ALTERNATIVES
In addition to the No Action alternative required for evaluation under the NCP, the
following alternatives have been developed as potential remedial actions for
contaminated sediment in the Area of Focus:
•
Alternative 1: Removal of Fine Grained Sediment from Area of Focus.
•
Alternative 2: Engineered Capping of Area of Focus.
•
Alternative 3: Engineered Capping of Area of Focus Following Reconstruction of
Federally Authorized Navigation Channel.
•
Alternative 4: Engineered Capping of Area of Focus Following Construction of
Navigation Channel to Accommodate Current Usage.
•
Alternative 5: Engineered Capping of Area of Focus Following Construction of
Navigation Channel to Accommodate Future Usage.
•
Alternative 6: Engineered Capping of Area of Focus Following Construction of
Navigation Channel to Accommodate Future Usage and Removal of Fine Grained
Sediment from the Primary Erosional Zone and the Primary Inventory Zone.
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The bases and assumptions used for conceptual design of these alternatives are discussed
below in Section 4.3.1 “Bases for Concept Development.” In addition, a detailed
description of each alternative is presented in Section 4.3.2 “Remedial Alternative
Descriptions.”
4.3.1
Bases for Concept Development
This section identifies the bases and assumptions associated with the selected process
options discussed in Section 4.2 “Selection of Representative Processes Options,” which
were used to conceptually design the alternatives identified in Section 4.3 “Development
of Remedial Alternatives.”
4.3.1.1
No Action
The No Action response does not include any containment, removal, disposal, or
treatment of contaminated sediment. It does, however, assume the continuation of
current institutional controls such as fish consumption advisories. It also includes the
five-year remedy reviews required under CERCLA Section 121(c).
4.3.1.2
Monitored Natural Recovery
As discussed in Section 3.3.3 “General Response Action: Monitored Natural Recovery,”
MNR may not be effective as the sole component of an early action, but could be
implemented as a component of alternatives comprising other active remedial measures.
Once active remediation is completed, deposition of contaminated sediment, originating
from freshwater flow over Dundee Dam and tidal exchange with Newark Bay, would
subsequently control contaminant concentrations on the sediment surface in the Lower
Passaic River. Natural recovery processes would serve to reduce the degree of
contamination associated with these deposited solids. For more information, refer to
Appendix D “Empirical Mass Balance Model.”
4.3.1.3
Sediment Removal
Mechanical dredging of contaminated sediments could involve the following steps:
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•
Dredging targeted sediments using a mechanical dredge fitted with an environmental
clamshell bucket.
•
Transporting the sediments to a processing or storage facility.
•
Processing the dredged material (e.g., dewatering, desiccating, and/or stabilizing).
•
Transporting the processed dredged material either for further treatment (e.g., thermal
treatment) and/or for placement (i.e., disposal and/or beneficial use).
•
Backfilling or capping of the dredged area.
Several major feasibility considerations drive the conceptual design, cost estimation, and
feasibility evaluation of alternatives involving dredging. These considerations, and the
relevant assumptions and bases used to address them, include:
•
Productivity: Based on the results of the Dredging and Decontamination Pilot Study
(Thompson et al., 2006), which utilized an environmental dredge equipped with an 8
cubic yard clamshell bucket to dredge sediments from the area near RM3 of the
Lower Passaic River, the production rate for one dredge has been assumed to be
2,000 cubic yards per 24-hour day.
•
Accuracy: The results of the Dredging and Decontamination Pilot Study (Thompson
et al., 2006) indicated that over 65 percent of the targeted area was dredged to within
six inches of the target elevation for single pass production dredging. Therefore, a
vertical accuracy of six inches has been assumed, and a one-foot over-dredging
allowance is used for volume estimates.
•
Resuspension: Based on an evaluation presented in Appendix E “Engineering
Memoranda,” dredge area containment has not been utilized in the conceptual
development of alternatives involving dredging. However, it is assumed that best
management practices and state of the art technology would be employed with the
objective of minimizing resuspension.
•
Residuals: As soon as practicable after removal of dredged sediment from each
dredge cell, backfill or capping material would be placed over the dredged area to
cover the exposed surface and dilute the residual layer. Based on inspection of
sediment profile imagery collected during the Dredging and Decontamination Pilot
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Study, the thickness of the dredging residual layer is assumed to be up to six inches.
Therefore, placement of a backfill layer with thickness of two feet is assumed.
•
Dredged Material Management: Appendix H “Dredged Material Management
Assessments” provides information and analysis of dredged material management
issues.
4.3.1.4
Sediment Containment
Several major feasibility considerations drive the conceptual design, cost estimation, and
feasibility evaluation of alternatives involving containment. These considerations, and
the relevant assumptions and bases used to address them, include:
•
Cap Material: Significant quantities of cap material will be required for alternatives
involving containment. For the purposes of estimating costs, it is assumed that a
nearby borrow source (either subaqueous or land-based) of coarse-grained sand will
be available. In light of the results of modeling of potential cap erosion (refer to
Appendix G “Cap Erosion and Flood Modeling”), the analyses performed to evaluate
the feasibility of containment alternatives have been based on the characteristics of
sand conforming to NJDOT specification I-7 (www.state.nj.us
/transportation/eng/specs/english/EnglishStandardSpecifications.htm#s90120).
•
Cap Placement: It is assumed that cap material will be placed on the river bed using
conventional equipment, either by hydraulic diffuser or clamshell bucket.
•
Cap Thickness: The conceptual design of an engineered cap in the Lower Passaic
River, in accordance with USEPA guidance, takes into account various requirements
for cap thickness. These requirements are presented in Figure 4-7 for the different
cap concepts used in developing the alternatives.
─ Thickness for chemical isolation (Ti): Based on the primary goal of reducing
particle-bound contaminant flux, a chemical isolation thickness of 12 inches was
assumed.
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─ Thickness for consolidation (Tc): Based on the granular, poorly-graded nature of
the representative material used for analysis, it is unlikely that significant
consolidation of the cap material itself would occur. It is likely that some
consolidation of the underlying material would occur, and a thickness of 6 inches
has been assumed to account for this (refer to Appendix E “Engineering
Memoranda”).
─ Thickness for bioturbation (Tb): Based on reporting from community surveys that
is still undergoing USEPA review (Tierra Solutions, Inc., 2006), in nearby areas
of the New York-New Jersey Harbor Estuary, it has been assumed that the benthic
community that might recolonize capped areas would be unlikely to burrow to
depths greater than 6 inches. If other species with deeper burrowing
characteristics (e.g., American Eel) were to colonize the capped area, sufficient
thickness exists beyond the bioturbation layer to maintain the integrity of the cap
despite burrowing.
─ Thickness for settlement (Ts): Some settlement of the cap materials into the
existing material may occur. However, literature suggests that use of hydraulic
diffuser equipment can minimize this settlement; hence, no additional cap
thickness has been assumed for settlement.
─ Thickness for erosion (Te): It is assumed that if 6 inches of erosion of capping
material were to occur, cap maintenance activities would be initiated. In addition,
armor material would be placed in areas prone to unacceptable erosion.
Therefore, for areas in which a cap would be constructed only of sand, six inches
has been assumed as an acceptable thickness for the erosion component; for areas
in which a cap would be armored to withstand erosive forces, the thickness for the
erosion component would be zero, as no erosion of sand material from underneath
the armor layer would be expected (refer to Appendix G “Cap Erosion and Flood
Modeling”).
•
Sand Cap Erosion/Armor Layer: The nature of a granular cap placed over the bed of a
large, tidally influenced riverine system is inherently dynamic. Under normal tidal
conditions, and particularly during extreme flow events, the granular material is
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expected to migrate to some extent. To investigate the nature of migration of an
engineered sand cap placed in the Lower Passaic River, and to determine whether the
extent and rate of migration are acceptable or require that an armor layer be placed,
cap erosion modeling was conducted as described in Appendix G “Cap Erosion and
Flood Modeling.” Based on the results of this modeling, certain capped areas in the
river would require armoring to reduce the erosion of the sand material. These areas
were selected based on the threshold of approximately 1 inch of maximum erosion
under the 100 year flow event. Using USACE guidance, a median stone size (d50) for
this armor material of 6 inches has been determined as suitable (refer to Appendix E:
“Engineering Memoranda”). Placement of a stone of this size would require that the
thickness of the armor layer be approximately 18 inches to ensure adequate coverage
of the sand, and may require that a filter material be placed on the sand prior to stone
placement to prevent settlement of the stone into the sand.
•
Cap Extent: Generally, the cap extent for alternatives involving containment
encompasses the entire Area of Focus; however, due to the depositional nature of
portions of the river, it is possible that discrete areas within the river could be shown
to be reliably depositional (even under storm flows).
•
Navigation: The construction of a navigation channel in the Lower Passaic River
would require the removal of sediment to at least the desired navigation depth, and
the volume of material removed would depend on the dimensions of the channel to be
constructed. In addition, in areas requiring placement of an engineered cap, removal
below the desired navigation depth in order to accommodate the necessary cap
components would be required. Table 4-1 (attached) portrays these cap components
and the associated depth of removal required. In the case where applying the
dimensions shown on Table 4-1 would remove all fine-grained sediment, the depth of
removal is limited to the depth of historical dredging (e.g., navigation channel depth
plus two feet) and the area would be remediated by dredging and backfilling instead
of capping. For example, in a case where the depth of the proposed navigation
channel will be 16 feet in a location where the constructed channel is 30 feet, the
depth of removal would be 25 feet (i.e., 16 feet plus 8 feet for cap construction plus 1
foot of overdredge allowance for inclusion in the volume estimate) and the location
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would be capped. Alternatively, in a case where the depth of the proposed navigation
channel will be 16 feet in a location where the constructed channel is 20 feet, the
depth of removal would be 23 feet (i.e., 20 feet plus 2 feet of historical overdredging
plus 1 foot of overdredge allowance for inclusion in the volume estimate) and the
location would be backfilled rather than capped.
•
Flooding Issues: To determine whether the placement of an engineered sand cap with
armor would result in additional flooding impact to the area surrounding the Lower
Passaic River, an analysis was conducted to evaluate the response of the water surface
elevation in the Lower Passaic River to the modified bathymetry and roughness
associated with alternatives involving containment (to reflect the placement of an
engineered cap) and to the hydrodynamic conditions present during an extreme event.
This analysis is described in Appendix G “Cap Erosion and Flood Modeling” and
summarized in Table 4-2. Based on guidance for remediation of contaminated
sediments (USEPA, 2005), this analysis focuses on the 100-year storm. The results
of the flood modeling demonstrate that changes in the bottom roughness and/or
bottom elevation can impact the total area flooded.
Table 4-2: Total Areas (acres) Flooded Under Different Remedial Scenarios
Base Case
8-Mile Cap
8-Mile Cap (Full Current
(Existing
(Armor Area
Predredging)
Navigation
Conditions)
Predredging)
Usage (Full
Predredging)
Future
Navigation
Usage (Full
Predredging)
100-Year Flow 499
592
523
523
482
Event
500-Year Flow 794
880
822
822
767
Event
100-Year Surge 1,249
1,249
1,249
1,249
1,249
Event
500-Year Surge 1,504
1,504
1,504
1,504
1,504
Event
Source: HydroQual Environmental Engineers & Scientists, 2007 (see Appendix G: “Cap Erosion and Flood
Modeling” for full report).
•
Pore Water Fluxes: Groundwater contaminant flux is probably a relatively minor
contributor of hydrophobic contaminants to the river, as compared to sediment
resuspension and transport, even when the ability of dissolved organic compounds to
enhance that groundwater flux is taken into account. This evaluation is based on
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professional judgment and the Lower Passaic River sediment’s high organic content,
because there is limited groundwater data for this river. Additional detail is provided
in the CSM (Appendix A “Conceptual Site Model”). The conceptual cap design
presented does not consider the treatment of groundwater or porewater.
•
Prop Wash: Erosive forces associated with engine prop wash have not been evaluated
in detail; however, incorporation of a buffer zone [as shown on Table 4-1 (attached)]
should minimize impacts to a cap.
•
Ice Scour: A limitation in colder regions is the potential erosion of a cap due to ice
jam formations. According to the Cold Regions Research and Engineering
Laboratory (CRREL) Ice Jam Database, there have been three ice jam events
recorded in the Passaic River at Chatham, New Jersey in the freshwater section of the
river. Although ice forms in the Lower Passaic River, no records of ice jams were
found in the Area of Focus. Therefore, cap erosion due to ice jams is not considered
a major concern for the Area of Focus. Although ice scour at the shoreline could be
an issue, it could be mitigated via biostabilization or installation of armoring
materials at the shoreline.
•
Wind/Wave Effects: The effects of wind/wave action on cap stability have not been
evaluated. Open water, deeper sites will be less influenced by wind or wave
generated currents and are generally less prone to erosion than shallow, nearshore
environments. However, armoring techniques or selection of erosion resistant
capping materials may make capping technically feasible in some higher energy
environments.
4.3.1.5
Ex Situ Treatment
Thermal destruction has been selected as the representative process option for ex situ
treatment because of the high treatment efficiencies for the types and concentrations of
contaminants present in the Area of Focus. Several thermal treatment options were
considered in developing conceptual remedial alternatives and cost estimates, as
discussed below:
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•
Construction of a local thermal treatment facility: It is assumed that a local thermal
treatment facility would be constructed on the same property as the sediment
processing facility at a near-river location. It has been assumed that capacity of the
facility, if constructed, would be sufficient to accept all material requiring treatment,
such that no other treatment options would be required. Cost estimates for
construction and operation of thermal treatment facilities of varying capacities were
obtained from thermal treatment vendors.
•
Transport to an existing, off-site, domestic facility: A limited number of domestic
thermal treatment facilities are capable of accepting PCDD/F-containing material.
Cost estimates associated with this thermal treatment option were based on rail
transport of contaminated sediments to permitted facilities in Deer Park, Texas and
Port Arthur, Texas. The facility in Deer Park, Texas is operated by Clean Harbors,
and has a capacity of approximately 250 tons per day. The Port Arthur facility is
operated by Onyx, and has a capacity of approximately 400 tons per day. Both of
these facilities are served by rail and have the required permits to treat PCDD/Fcontaminated sediment, provided that the sediment is not an F-listed PCDD/F waste.
For this analysis, it was assumed that each facility could dedicate approximately 40
percent of their daily capacity to the Lower Passaic River, so that the Deer Park
facility could accept 100 tons per day, and the Port Arthur facility could accept 150
tons per day. This quantity equates to a total domestic thermal treatment capacity of
approximately 90,000 tons per year.
•
Transport to an existing, off-site, international facility: Bennett Environmental
operates a thermal treatment facility capable of treating PCDD/F-containing waste.
Cost estimates are based on rail transport to the facility located in Ontario, Canada,
which has an annual capacity of 100,000 tons per year. For this analysis, it is
assumed that Bennett could dedicate 100 percent of their capacity to treating material
from the Lower Passaic River.
It is important to note that for projects utilizing multiple dredges, the combined use of
both existing domestic and existing international facilities may not be sufficient to treat
all of the contaminated sediments (i.e., the volume of sediment deemed to require thermal
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treatment based on a material stream distribution analysis). Although storage space could
offset the deficit in throughput capacity, facility operators have indicated that off-site
storage capacity is minimal. Given the uncertainties associated with throughputs for offsite thermal treatment facilities, it has been assumed that a local thermal treatment facility
would be constructed to treat the dredged sediment. For purposes of remedial alternative
and cost estimate development, it has been assumed that the Cement-Lock® thermal
process would be applied.
It would be necessary to dewater the dredged material prior to thermal treatment. The
average in situ sediment solids content measured by sediment coring associated with the
Dredging and Decontamination Pilot Study was approximately 42.5 percent (TAMS and
Malcolm Pirnie, Inc., 2005a). Mechanical dredging will result in additional water
entrainment, lowering the percent solids of the recovered sediment. Therefore, for cost
estimating purposes, it was assumed that the initial solids content of the dredged sediment
is 25 percent, and that the post-dewatering solids content is 50 percent.
4.3.1.6
Disposal of Dredged Sediments
As discussed in Section 4.2 “Selection of Representative Process Options,” nearshore
CDFs have been selected as a process option for sediment disposal. Construction of a
CDF would require containment measures such as sheet-piling. The CDF could be used
for storage and passive dewatering of dredged sediment. A leachate collection system
could be constructed to collect and channel effluent to a treatment system. As a final use,
the dewatered sediment in the CDF could be removed for thermal treatment, or it could
be permanently capped to create land for a beneficial use such as a park or development.
One advantage of using a nearshore CDF for temporary storage is that a smaller thermal
treatment plant could be constructed at a lower capital cost and sediment could be treated
over a longer time. With an assumed footprint of 100 acres and a depth of 10 feet, a
nearshore CDF could accommodate approximately 1.7 million cubic yards of sediment.
If the CDF were to be excavated by 20 feet, 40 feet, or 60 feet, it could accommodate
approximately 5 million, 8 million, and 11 million cubic yards of sediment, respectively.
These volumes would accommodate the sediment capacity required for each remedial
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alternative discussed in Section 4.3.2 “Remedial Alternative Descriptions” below. For
costing purposes, it is assumed that for alternatives where additional capacity is required
(beyond the 10-foot initial depth), the first five feet of excavated material is assumed to
be contaminated, and it would be dredged and placed in a ‘starter cell’ of the CDF. Any
additional deeper material could be dredged and disposed of in an ocean disposal area.
Two dredged material management scenarios incorporating nearshore CDF disposal are
considered in developing the alternative specific cost estimates presented in Appendix J
“Cost Estimates.” Dredged Material Management Scenario A assumes that all dredged
material would be permanently disposed of in a CDF. Dredged Material Management
Scenario B assumes that all dredged material would initially be placed in a CDF, but the
volume stored above the original mudline grade (prior to excavation within the CDF
footprint), would be dewatered and treated by an onsite thermal treatment facility. The
volume to be thermally treated under Scenario B is up to approximately 1.7 million cubic
yards. When necessary to provide the required capacity, excavation below the mudline
(within the footprint of the CDF) would be performed.
One additional dredged material management scenario that could be considered is
treating all dredged material via thermal destruction. For alternatives where dredging
volumes are low (i.e., Alternatives 2 and 4), the cost difference between CDF disposal
and thermal treatment is minimal (the thermal treatment cost is offset by capital savings
for the construction of the CDF). For alternatives where greater volumes are generated
(i.e., Alternatives 1, 3, 5, and 6), the additional cost for thermal treatment of all material
is approximately $30 to $40 per cubic yard (on an in situ basis) above the cost of dredged
material management Scenario B.
4.3.1.7
Additional Considerations
This section discusses additional elements of the remedial alternatives that are not
considered process options, but that are considered integral parts of the remedial action
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alternatives. These items are included in all active alternatives and their associated costs
are provided in Appendix J “Cost Estimates.”
Pre-Design Investigation: The purpose of the pre-design investigation would be to
provide current data on sediment conditions prior to initiation of remedial design. The
pre-design investigation program would involve sediment sampling for chemical and
geotechnical parameters. For alternatives involving sediment removal, it is assumed that
cores for chemical analysis would be collected on an 80-foot triangular grid, and cores
for geotechnical analysis would be collected on a 160-foot triangular grid. For
alternatives involving containment, it is assumed that cores for both chemical and
geotechnical data needs would be spaced on a 160-foot triangular grid (cores for
chemical analysis will be collected only from areas of planned sediment removal).
Coring depths for chemical and geochemical samples would vary depending on the
planned sediment removal depth for each alternative, and depending on whether shoreline
and utility protection structures would be utilized. Details regarding assumed depths of
cores and numbers of samples to be collected per core are included in the cost estimate
assumptions provided in Appendix J “Cost Estimates.” Geophysical data including
sediment type, texture, thickness, and elevation would be collected using techniques such
as cone penetrometer testing (CPT), side-scan sonar and bathymetric surveys of the target
area. A video survey would be incorporated in the pre-design investigation to identify
debris in the target area.
Permitting, Design, and Contractor Work Plans: Permitting for an early action, if
selected, would begin during the pre-design investigation phase, and should be completed
prior to the start of construction. Typically, CERCLA response actions are exempted by
law from the requirement to obtain federal, state, or local permits related to any activities
conducted completely on-site; however, this exemption does not remove the requirement
to meet (or waive) the substantive provisions of the regulations that are ARARs. Also,
permits may be required for dredged material management facilities that are not located
‘on-site’.
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Upon completion of the pre-design work, a final design incorporating specifications and
drawings would be prepared, and a contractor would be selected to perform the
construction work. The contractor would be required to prepare its work plans detailing
operational parameters for equipment to be used, quality assurance and quality control
procedures, safety procedures, work schedules, and other items, as required. The costs
for contractor work plans are based upon the size of the projects proposed in each
remedial alternative.
Mobilization/Demobilization and Annual Shutdown/Startup: After completion of preconstruction activities, the contractor would mobilize required equipment to the site. For
cost estimation purposes, it is assumed that the type, size, and number of equipment and
monitoring vessels is assumed to vary based on the processes utilized for each alternative.
The types of equipment and vessels that may be mobilized include the following:
•
Dredges.
•
Scows for holding and transporting dredged material.
•
Clamshell buckets, diffusers, or spreaders for cap placement.
•
Steel sheeting and barge-mounted vibratory hammer for alternatives involving
shoreline protection. (It is assumed that, in areas of existing bulkheads and shoreline
structures, as well as bridge abutments, protection via sheet-pile would be utilized.)
•
Debris removal equipment.
•
Hydrographic survey vessels.
•
Geophysical vessel(s).
•
Sampling (Vibracoring) vessel(s).
Demobilization involves removing all equipment from the staging and work areas and
meeting any requirements for decontamination or verification of the acceptable status of
the processing areas. It is assumed that full demobilization will not be required every
year; however, to account for the potential for an extended period of seasonal or weatherrelated downtime, the cost of an annual shutdown/startup of construction operations has
been included.
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Debris Management: Prior to implementing any remedial activity, it would be necessary
to remove large debris from the sediment surface to streamline subsequent dredging
and/or capping operations. A side-scan sonar survey performed by Aqua Survey, Inc.
(2006) in 2004, identified 47 large objects, 16 of which had signatures of automobiles. A
shipwreck was also identified. These data were used as a rough indication of the amount
of debris that may be encountered for purposes of the cost estimate. Further, to account
for the possibility of sub-surface debris not identified by the side-scan sonar survey, the
quantity of debris requiring removal was assumed to increase corresponding to an
increase in depth of sediment removal. It was assumed that debris removal would
proceed at a rate of approximately 100 tons per day until the estimated quantities were
removed, and that the debris would be classified as non-hazardous waste. Estimates of
debris removal quantities and management costs are provided in Appendix J “Cost
Estimates.” A video survey would be performed during the pre-design investigation to
refine the debris management estimates.
Dredged Sediments Processing Facility: The characteristics of a suitable sediment
processing location include adequate river frontage for supporting barge operations,
sufficient land for materials processing and storage, and access to rail facilities. For
purposes of the cost estimate, it is assumed that a waterfront processing facility will be
located within the Port of New York and New Jersey district.
A preliminary study was conducted to identify potential sites for the development of
either a processing facility or placement site to handle dredged material from the Lower
Passaic River (USACE, 2006b and Appendix H “Dredge Material Management
Assessments”). The extent of the study covered a 15-mile radius around the waterfront
portions of the area between RM2.4 and RM4.6 of the Lower Passaic River. Factors
influencing potential site identification included site accessibility and land use. Water,
rail, and road access were evaluated for each site, including presence of piers/bulkheads,
water depths, paved roads, proximity to major highways, and distance to rail lines or
spurs. Land use considerations included the existence of vacant lots, open space, and
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degree of development. Other considerations included confirmation of loading/docking
facilities, nearby bridge heights, and location of residential areas.
A total of 87 potential placement or processing sites were identified within the extent of
the study. Nineteen large (greater than 50 acres) sites were identified. Of these, eight
sites are within ten miles of the area between RM2.4 and RM4.6. There exist several
sites of suitable size within an acceptable distance of the Lower Passaic River so as to be
considered potentially feasible as processing or placement sites. Future site screening
will be necessary in order to narrow down site location options and distinguish those sites
with characteristics most desirable for processing and those sites with characteristics
most desirable for placement.
Scows would deliver the dredged material to the processing facility. Material in the
scows would be off-loaded by conventional methods such as a crane or excavator. Prior
to unloading the scows, excess water that has accumulated above the incoming sediments
would be pumped off, treated, and discharged back to the river (or other adjacent water
body or POTW). Once the dredged material has been off-loaded, it would be processed
to improve its handling and shipping characteristics. The precise nature and degree of
processing would depend on sediment characteristics, and the requirements of the
applicable dredged material management option (i.e., thermal treatment or placement).
Construction Monitoring Program: Development of the construction monitoring program
is based on the resuspension monitoring procedures used for the Environmental Dredging
Pilot Study (TAMS and Malcolm Pirnie, 2005b; Bilimoria et al., 2006). Appropriate data
quality objectives (DQOs) for the construction monitoring program would be developed
during the design phase of the project.
During the construction period, water quality in the vicinity of construction operations
would be monitored. It is assumed that two sampling vessels, one positioned upstream
and one downstream of the construction equipment, would be used to collect water
quality samples. All of the surface water samples would be analyzed for total suspended
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solids, and a subset of samples may also be analyzed for a limited suite of other water
quality parameters or contaminants of concern.
Confirmatory sampling for alternatives involving placement of backfill or capping
material would be implemented to document a sufficient thickness of material and
characterize the contaminant distribution at and around the interface between the existing
sediment and cap material. This task has been estimated assuming that 4-foot cores
would be taken at a frequency of 5 cores per transect placed at 0.1-mile intervals.
The depth of sediment removed as well as the depth of backfill or capping material
placed would also be monitored using methods such as CPT, bathymetry, and acoustic
imaging of the sediment type (side-scan sonar).
Ecological monitoring would be performed during the course of construction to assess the
impact on the biological community within the Area of Focus, as well as upriver and
downriver of this area. Monitoring would include terrestrial, avian, and aquatic (i.e., fish,
benthic, and submerged vegetative) communities, as well as biological tissue analysis and
toxicity testing.
Post-Construction Monitoring Program: A post-construction monitoring program would
be performed for each alternative. Based on USEPA guidance, costs are included for a
period of thirty years of monitoring for each alternative (USEPA, 1988). Appropriate
DQOs would be developed during the design phase. The purpose of the postconstruction monitoring program would be to document the performance of the selected
remedial measures in reducing COPC and COPEC concentrations in the water, sediment,
and biota associated with the Lower Passaic River. Therefore, for the purposes of
conceptual design and cost estimation, this program involves the sampling of all three
media. For surface sediment sampling, it is assumed that five samples are collected per
transect, spaced at 0.1-mile intervals throughout the Area of Focus. The water quality
program is assumed to entail the collection of two surface water samples taken for 2 tidal
cycles per river mile. Ecological monitoring would be performed to identify the impacts
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of the construction on the habitat and biological communities, and the changes and
recovery that occur over the 30 year monitoring period. Avian, fish, benthic, and
biological tissue samples would be collected at appropriate locations and frequencies.
Each year, the post-construction ecological monitoring data would be assessed to
determine if certain aspects of the program may be reduced to biannual (or less frequent)
monitoring during future sampling events, or if the analyte list may be reduced.
Additional details for the ecological monitoring program would be developed in an
Ecological Monitoring Plan.
Techniques such as CPT would be conducted at least annually to monitor changes in the
installed fill and capping material to identify areas undergoing scour or deposition. These
data would be used to assess the long-term integrity of the cap for alternatives involving
capping. Additional cap material would be placed in those areas in which the thickness
of the cap is observed to have decreased by 6 inches or more to maintain a suitable cap
thickness. In addition, sediment profile imaging (SPI) would be performed to monitor
habitat recolonization.
Restoration: The implementation of a remedial alternative in the Area of Focus would
impact existing habitat conditions. As part of the reconstruction of the remediated area,
substrate would be placed that would be suitable for future activities relating to habitat
restoration. Certain types of restoration would likely be feasible to integrate with a
remedial action, including riparian fringe restoration, mudflat reconstruction, and benthic
habitat creation. In addition, biostabilization techniques could be considered as an
alternative erosion protection measure and could have the added benefit of providing
submerged aquatic or tidal emergent habitat.
At present, there are efforts planned by the USACE to develop a Focused Restoration
Plan as a companion to early action alternatives (refer to www.ourpassaic.org for
additional information regarding restoration).
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4.3.2
Remedial Alternative Descriptions
In this section, each of the six active remedial alternatives introduced in Section 4.3
“Development of Remedial Alternatives,” and developed using the bases and
assumptions provided in Section 4.3.1 “Bases for Concept Development,” is described in
detail. Table 4-3 (attached) provides a summary of the remedial alternatives.
4.3.2.1
Alternative 1: Removal of Fine Grained Sediment from Area of Focus
Alternative 1 would use mechanical dredging to remove fine-grained sediment from the
Area of Focus.
Within the horizontal limits of the federally authorized navigation channel, the depth of
fine-grained sediment corresponds well with the depth of historical dredging. For this
reason, the depth of dredging within these horizontal limits is assumed to be the
historically constructed channel depth plus an additional three feet to account for
historical overdredging (two feet) and dredging accuracy (one foot).
Outside of the horizontal limits of the federally authorized navigation channel, the depth
of fine-grained sediment varies. Therefore, data from geotechnical cores and chemical
cores were used to estimate the depth of the fine-grained sediment boundary at various
locations in the river. The depth of dredging at each of these locations is the estimated
depth of fine-grained sediment plus an additional one foot to account for dredging
accuracy.
The objective of Alternative 1 is to remove as much of the fine-grained sediment as
practicable, resulting in the exposure of the underlying sandy material. As soon as
practicable after exposure of this sandy material, two feet of backfill material would be
placed to mitigate residual contamination. The thickness of this backfill material would
not be monitored or maintained following implementation.
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The dredged material removed during implementation of Alternative 1 would be placed
into a nearshore CDF. After the material is passively dewatered, it may either be
removed from the CDF for thermal treatment, or it may be permanently capped in place.
After construction is completed, this alternative relies on institutional controls, such as
fish consumption advisories, while monitored natural recovery processes act to reduce the
concentration of the remaining contamination until the Remedial Action Objectives are
achieved. A long-term monitoring program would be implemented to verify that the river
is responding with reduced contamination levels over the long term. A review of Site
conditions would be conducted at five-year intervals, as required by CERCLA.
The conceptual design of Alternative 1 is shown on Figure 4-1. Additional detail is also
provided in Table 4-3 (attached).
4.3.2.2
Alternative 2: Engineered Capping of Area of Focus
Alternative 2 would sequester the contaminated sediments in the Area of Focus under an
engineered cap. Minimal removal of contaminated sediments, for the purposes of
mudflat reconstruction and armor placement only, is assumed for Alternative 2.
The cap would be constructed of sand, stone, and mudflat reconstruction material. Over
approximately 80 percent of the sediment surface area, the cap would be constructed of
sand alone. In areas of unacceptable erosion, estimated to be approximately 20 percent of
the river surface in Appendix G “Cap Erosion and Flood Modeling,” stone would be used
as armor material. In select small areas of the river, existing mudflats would be
reconstructed by removing four feet of contaminated sediment, placing two feet of sand
as substrate, and placing two feet of mudflat reconstruction material.
It has been assumed that placement of sand material would be conducted using
conventional methods, which would be capable of minimizing the amount of settlement
of the sand material into the existing silt. Placement of armor material would be achieved
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using mechanical methods. Due to the proximity to shore, mudflat reconstruction
material would likely be placed via mechanical equipment.
The thickness of the engineered cap would be monitored and maintained following
implementation as part of the annual Post-Construction Monitoring Program (as
described in Section 4.3.1.7 “Additional Considerations”).
Flood modeling as described in Section 4.3.1.4 “Sediment Containment” and Appendix G
“Cap Erosion and Flood Modeling,” has shown that pre-dredging prior to cap placement
does not substantially reduce the total area flooded. Therefore, pre-dredging in areas to
be capped has not been incorporated into Alternative 2.
The dredged material removed during implementation of Alternative 2 would be placed
into a nearshore CDF. After the material is passively dewatered, it may either be
removed from the CDF for thermal treatment, or it may be permanently capped in place.
After construction is completed, this alternative relies on institutional controls, such as
fish consumption advisories and restrictions on activities that could compromise the
integrity of the cap, while monitored natural recovery processes act to reduce the
concentration of the remaining contamination until the Remedial Action Objectives are
achieved. A long-term monitoring program would be implemented to verify the integrity
of the cap, ensure that the thickness of the cap is maintained and verify that the river is
responding with reduced contamination levels over the long term. If any portion of the
cap became eroded, it would require replacement. A review of Site conditions would be
conducted at five-year intervals, as required by CERCLA.
The conceptual design of Alternative 2 is shown on Figure 4-2. Additional detail is also
provided in Table 4-3 (attached).
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4.3.2.3
Alternative 3: Engineered Capping of Area of Focus Following
Reconstruction of Federally Authorized Navigation Channel
The dimensions of the federally authorized navigation channel are provided in Section
4.1.3.1 “Current Federally Authorized and Constructed Navigational Channel Depths.”
Alternative 3 would use mechanical dredging to remove sediment from within the
horizontal limits of the federally authorized navigation channel. The depth of dredging
within these horizontal limits is assumed to be the historically constructed channel depth
plus an additional three feet to account for historical overdredging (two feet) and
dredging accuracy (one foot). The sediment surface between the bottom of the dredged
channel and the existing sediment surface (“sideslope”) would be constructed at a slope
of 3 horizontal to 1 vertical (3H:1V).
After sediments are removed from the federally authorized navigation channel to the
depth specified above, it is assumed that a minimal amount of fine-grained sediment
would remain in the channel. Therefore, a two-foot backfill layer would be placed to
mitigate remaining fine-grained sediment and dredging residuals. The thickness of this
backfill material would not be monitored or maintained following implementation.
Outside of the horizontal limits of the federally authorized navigation channel, however,
it is possible that additional, un-targeted contaminant inventory would remain in place.
For this reason, it is assumed that an engineered cap would be placed on the sideslopes,
as well as on the existing sediment surface between the channel and the shoreline
(“shoal”). In areas of unacceptable erosion on the sideslopes and/or shoals, as identified
in Appendix G “Cap Erosion and Flood Modeling,” stone would be used as armor
material. The thickness of the engineered cap would be monitored and maintained
following implementation as part of the annual Post-Construction Monitoring Program
(as described in Section 4.3.1.7 “Additional Considerations”).
The dredged material removed during implementation of Alternative 3 would be placed
into a nearshore CDF. After the material is passively dewatered, it may either be
removed from the CDF for thermal treatment, or it may be permanently capped in place.
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After construction is completed, this alternative relies on institutional controls, such as
fish consumption advisories and restrictions on activities that could compromise the
integrity of the cap, while monitored natural recovery processes act to reduce the
concentration of the remaining contamination until the Remedial Action Objectives are
achieved. A long-term monitoring program would be implemented to verify the integrity
of the cap, ensure that the thickness of the cap is maintained and verify that the river is
responding with reduced contamination levels over the long term. If any portion of the
cap became eroded, it would require replacement. A review of Site conditions would be
conducted at five-year intervals, as required by CERCLA.
The conceptual design of Alternative 3 is shown on Figure 4-3. Additional detail is also
provided in Table 4-3 (attached).
4.3.2.4
Alternative 4: Engineered Capping of Area of Focus Following
Construction of Navigation Channel to Accommodate Current Usage
As described in Section 4.1.3.2 “Navigational Channel Dimensions to Accommodate
Current Usage,” USACE-New York District has estimated the dimensions of the
navigation channel necessary to accommodate current usage. Alternative 4 would use
mechanical dredging to construct a channel of these dimensions, and subsequently place
an engineered cap over the entire Area of Focus.
From RM0 to RM1.2, the depth of dredging within the horizontal limits of the federally
authorized navigation channel is assumed to be the historically constructed channel depth
(30 feet MLW) plus an additional three feet to account for historical overdredging (two
feet) and dredging accuracy (one foot). The sideslope would be constructed at a slope of
3H:1V. After sediments are removed from the federally authorized navigation channel to
the depth specified above, it is assumed that a minimal amount of fine grained sediment
would remain in the channel. Therefore, a two-foot backfill layer would be placed to
mitigate remaining fine grained sediment and dredging residuals. The thickness of this
backfill material would not be monitored or maintained following implementation.
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From RM1.2 to RM2.5, the depth of dredging within the horizontal limits of the federally
authorized navigation channel is assumed to be the depth required by the design vessel
(13 feet), plus an additional three feet for underkeel clearance, plus an additional nine feet
to accommodate the necessary cap components that would be placed. The sideslope
would be constructed at a slope of 3H:1V. Following removal to the depth described
above, it is possible that additional, un-targeted contaminant inventory could remain in
place. Therefore, an engineered cap would be placed on the channel bottom. The
thickness of the engineered cap would be monitored and maintained following
implementation as part of the annual Post-Construction Monitoring Program (as
described in Section 4.3.1.7 “Additional Considerations”).
In the sideslope and shoal areas of RM0 to RM2.5, and throughout the rest of the Area of
Focus from RM2.5 to RM8, it is likely that additional, un-targeted contaminant inventory
would remain in place. Therefore, pre-dredging to accommodate an engineered cap
would be necessary in these areas. In areas of unacceptable erosion, as identified in
Appendix G “Cap Erosion and Flood Modeling,” stone would be used as armor material.
The dredged material removed during implementation of Alternative 4 would be placed
into a nearshore CDF. After the material is passively dewatered, it may either be
removed from the CDF for thermal treatment, or it may be permanently capped in place.
After construction is completed, this alternative relies on institutional controls, such as
fish consumption advisories and restrictions on activities that could compromise the
integrity of the cap, while monitored natural recovery processes act to reduce the
concentration of the remaining contamination until the Remedial Action Objectives are
achieved. A long-term monitoring program would be implemented to verify the integrity
of the cap, ensure that the thickness of the cap is maintained and verify that the river is
responding with reduced contamination levels over the long term. If any portion of the
cap became eroded, it would require replacement. A review of Site conditions would be
conducted at five-year intervals, as required by CERCLA.
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The conceptual design of Alternative 4 is shown on Figure 4-4. Additional detail is also
provided in Table 4-3 (attached).
4.3.2.5
Alternative 5: Engineered Capping of Area of Focus Following
Construction of Navigation Channel for Future Use
As described in Section 4.1.3.3 “Navigational Channel Depths to Accommodate ‘Future
Usage,’” the State of New Jersey has estimated the dimensions of the navigation channel
necessary for future river traffic. Alternative 5 would use mechanical dredging to
construct a channel of these dimensions, and place an engineered cap or backfill over the
Area of Focus.
From RM0 to RM1.2, the depth of dredging within the horizontal limits of the federally
authorized navigation channel is assumed to be the historically constructed channel depth
(30 feet MLW) plus an additional three feet to account for historical overdredging (two
feet) and dredging accuracy (one foot). The channel sides would be constructed at a
slope of 3H:1V. After sediments are removed from the federally authorized navigation
channel to the depth specified above, it is assumed that a minimal amount of fine grained
sediment would remain in the channel. Therefore, a two foot backfill layer would be
placed to mitigate remaining fine grained sediment and/or dredging residuals. The
thickness of this backfill material would not be monitored or maintained following
implementation.
From RM1.2 to RM2.5, the depth of dredging within the horizontal limits of the federally
authorized navigation channel is assumed to be the depth required by the design vessel
(13 feet), plus an additional three feet for underkeel clearance to achieve the channel
depth of 16 feet MLW, plus an additional nine feet to accommodate the necessary cap
components that would be placed. The channel sides would be constructed at a slope of
3H:1V. Following removal to the depth described above, it is possible that additional,
un-targeted contaminant inventory would remain in place. Therefore, an engineered cap
would be placed on the channel bottom. The thickness of the engineered cap would be
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monitored and maintained following implementation as part of the annual PostConstruction Monitoring Program (as described in Section 4.3.1.7 “Additional
Considerations”).
From RM2.5 to RM3.6, the depth of dredging within the horizontal limits of the federally
authorized navigation channel is assumed to be the historically constructed channel depth
(20 feet MLW) plus an additional three feet to account for historical overdredging (two
feet) and dredging accuracy (one foot). The sideslope would be constructed at a slope of
3H:1V. After sediments are removed from the federally authorized navigation channel to
the depth specified above, it is assumed that a minimal amount of fine grained sediment
would remain in the channel. Therefore, a two-foot backfill layer would be placed to
mitigate remaining fine grained sediment and dredging residuals. The thickness of this
backfill material would not be monitored or maintained following implementation.
From RM3.6 to RM8.3, the depth of dredging within the horizontal limits of the federally
authorized navigation channel is assumed to be the depth required by the design vessel
(seven feet), plus an additional three feet for underkeel clearance, plus an additional nine
feet to accommodate the necessary cap components that would be placed. This
alternative will require sediment removal to 19 feet MLW. However, the depth of the
authorized historical channel from RM8.1 to RM8.3 is 10 feet. An addition of three feet
to the authorized depth to account for historical overdredging (two feet) and dredging
accuracy (one foot) result in a historical channel depth of 13 feet MLW (not 19 feet
MLW). Since dredge depth is limited to the historical channel depth, it is assumed that
sediment will be removed to a depth of 13 feet MLW from RM8.1 to RM8.3. Following
removal to the depth described above (i.e., 19 feet MLW from RM3.6 to RM8.1 and 13
feet from RM8.1 to RM8.3), it is possible that additional, un-targeted contaminant
inventory would remain in place from RM3.6 to RM4.6; however, it is assumed that
minimal fine-grained sediment would remain in the channel from RM4.6 to RM8.3.
Therefore, an engineered cap would be placed on the channel bottom from RM3.6 to
RM4.6 and a two foot backfill layer would be placed to mitigate for any remaining finegrained sediment and/or dredging residuals from RM4.6 to RM8.3. The side slope would
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be constructed at a slope of 3H:1V. The thickness of the engineered cap would be
monitored and maintained following implementation as part of the annual PostConstruction Monitoring Program (as described in Section 4.3.1.7 “Additional
Considerations”), but the backfill layer would not be maintained.
In the sideslope and shoal areas of RM0 to RM8, it is likely that additional, un-targeted
contaminant inventory would remain in place. For this reason, it is assumed that an
engineered cap would be placed in these areas. In areas of unacceptable erosion, as
identified in Appendix G “Cap Erosion and Flood Modeling,” stone would be used as
armor material. The thickness of the engineered cap would be monitored and maintained
following implementation as part of the annual Post-Construction Monitoring Program
(as described in Section 4.3.1.7 “Additional Considerations”).
Flood modeling as described in Section 4.3.1.4 “Sediment Containment” and Appendix G
“Cap Erosion and Flood Modeling” has shown that pre-dredging prior to cap placement
would reduce the total area flooded to below the acreage flooded under the base case.
Therefore, pre-dredging in areas to be capped has been incorporated into Alternative 5.
The dredged material removed during implementation of Alternative 5 would be placed
into a nearshore CDF. After the material is passively dewatered, it may either be
removed from the CDF for thermal treatment, or it may be permanently capped in place.
After construction is completed, this alternative relies on institutional controls, such as
fish consumption advisories and restrictions on activities that could compromise the
integrity of the cap, while monitored natural recovery processes act to reduce the
concentration of the remaining contamination until the Remedial Action Objectives are
achieved. A long-term monitoring program would be implemented to verify the integrity
of the cap, ensure that the thickness of the cap is maintained and verify that the river is
responding with reduced contamination levels over the long term. If any portion of the
cap became eroded, it would require replacement. A review of Site conditions would be
conducted at five-year intervals, as required by CERCLA.
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The conceptual design of Alternative 5 is shown on Figure 4-5. Additional detail is also
provided in Table 4-3 (attached).
4.3.2.6
Alternative 6: Engineered Capping of Area of Focus Following
Construction of Navigation Channel for Future Use and Removal of Fine Grained
Sediment from Primary Inventory Zone and Primary Erosional Zone
The conceptual design of Alternative 6 is identical to that of Alternative 5, with the
exception that, in the Primary Erosional Zone and the Primary Inventory Zone, the depth
of dredging is assumed to be the estimated depth of fine grained sediment plus an
additional one foot to account for dredging accuracy.
After construction is completed, this alternative relies on institutional controls, such as
fish consumption advisories and restrictions on activities that could compromise the
integrity of the cap, while monitored natural recovery processes act to reduce the
concentration of the remaining contamination until the Remedial Action Objectives are
achieved. A long-term monitoring program would be implemented to verify the integrity
of the cap, ensure that the thickness of the cap is maintained and verify that the river is
responding with reduced contamination levels over the long term. If any portion of the
cap became eroded, it would require replacement. A review of Site conditions would be
conducted at five-year intervals, as required by CERCLA.
The conceptual design of Alternative 6 is shown on Figure 4-6. Additional detail is also
provided in Table 4-3 (attached).
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5.0
DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES
This section presents a detailed analysis of the remedial alternatives described in Section
4.0 “Development of Remedial Action Alternatives.” In addition to the No Action
alternative, the six active remedial alternatives presented in Section 4.3.2 “Remedial
Alternative Descriptions” are evaluated.
Section 5.1 “Evaluation Process and Evaluation Criteria” presents a description of each
criterion and a discussion of how each criterion will be applied to evaluate the remedial
alternatives. As the six active remedial alternatives were developed using the same set of
process options, this section often relies on a discussion of how criteria apply to these
process options.
Section 5.2 “Analysis of Alternatives” presents a detailed analysis of the individual
alternatives in reference to the evaluation criteria (see Table 5-1) and a comparative
analysis to evaluate the relative performance of alternatives in relation to each evaluation
criterion. Comparisons are made either between the set of active alternatives and the No
Action alternative, or by comparing the active alternatives to one another.
5.1
EVALUATION PROCESS AND EVALUATION CRITERIA
Nine criteria are used to address the CERCLA requirements for analysis of remedial
alternatives. The first two criteria are threshold criteria that must be met by each
alternative. The next five criteria are the primary balancing criteria upon which the
analysis is based. The final two criteria, referred to as modifying criteria, are typically
applied following the public comment period for the Proposed Plan to evaluate state and
community acceptance. The following sections describe each criterion and the manner in
which it is interpreted for the individual and comparative remedial alternatives analyses.
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5.1.1
Threshold Criteria
5.1.1.1
Overall Protection of Human Health and the Environment
This criterion requires that each alternative adequately protect human health and the
environment. It draws on the assessments conducted under other evaluation criteria,
especially long-term effectiveness and permanence, short-term effectiveness, and
compliance with ARARs. These criteria are discussed below and in Section 5.1.2
“Primary Balancing Criteria.”
5.1.1.2
Compliance with ARARs
Alternatives are assessed as to whether they attain federal and state ARARs, including:
•
Location-specific ARARs (e.g., requirements for construction in the coastal zone or
wetlands).
•
Action-specific ARARs (e.g., requirements for transportation of hazardous waste).
No chemical-specific ARARs were found to be applicable to this remedial action. Refer
to Section 2.3 “Development of ARARs” for a compilation and discussion of the
ARARs.
None of the identified action-specific or location-specific ARARs are applicable to the
No Action alternative.
The six active alternatives were analyzed for compliance with ARARs by dividing each
alternative into seven different elements or activities. These elements are described in the
following list. Each bullet highlights some of the aspects of each element which will be
applicable to the identified ARARs.
•
Pre-construction Activities: This element involves the collecting, processing, and
analyzing of numerous sediment cores for chemical and geotechnical properties. This
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element also includes the decontamination of equipment and the disposal of
contaminated investigation derived waste (IDW).
•
Construction and Operation of a Support Area: The site is assumed to be near the
river and includes a dock and boat launch, and possibly some structures for housing
equipment and supplies. These facilities could be portable rented units, or could
involve the construction of permanent new facilities.
•
Dredging: Each of the active alternatives being considered includes some degree of
sediment removal. This element includes the installation of sheet piling for
protection of bulkheads, bridges, docks, and utilities. Dewatering of the dredged
material and the resuspension of sediment material will also result from this activity.
•
Capping: This element includes the placement of engineered caps, backfilling,
armoring, and mudflat reconstruction in some areas of the river.
•
CDF Construction and Operation: This element includes the installation of sheet
piling, potential deep excavation of the disposal area, and transportation and
offloading of dredged sediments into the CDF via mechanical or hydraulic means.
This element also includes activities for closing the CDF once the project is
completed.
•
Thermal Treatment: This element includes the construction of an on-site thermal
treatment plant, transportation of sediments from the CDF to the treatment works, and
activities involved with the permanent treatment of the contaminated sediment such
as control of air emissions resulting from the process.
•
Wastewater Treatment and Discharge: Options for this element are treatment and
discharge of wastewater; pretreatment of wastewater and discharge to a POTW or to
the river; or discharge to a POTW without pretreatment. This element includes the
construction and operation of an on-site treatment facility or the acquisition of a
package treatment facility, if needed.
Table 5-2 lists the ARARs and their statutory or regulatory citations for each of the seven
remediation elements described above. This table also presents the rationale for the parts
of each element of the remediation process that will fall under each ARAR.
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Each ARAR will be considered in detail during the design phase to provide for
compliance during construction and remediation.
5.1.2
Primary Balancing Criteria
5.1.2.1
Long-Term Effectiveness and Permanence
The long-term effectiveness and permanence criterion addresses the results of a remedial
action in terms of the risk remaining at the site after response objectives have been met.
Factors that should be considered, according to the NCP and RI/FS guidance (USEPA,
1988) are as follows:
•
Magnitude of residual risks in terms of amounts and concentrations of contaminated
sediment remaining following the implementation of a remedial action.
•
Long-term reliability and adequacy of the engineering and institutional controls,
including uncertainties pertaining to land disposal of contaminated sediment and
residuals.
The approach for assessing each of these factors is summarized below. For the purposes
of this evaluation, it is assumed for each active alternative that the long-term period
begins after remedial actions are completed in 2018.
Magnitude of Residual Risk: To evaluate the magnitude of residual risk present
following remediation of the Area of Focus, the calculations provided in Section 8 of
Appendix C “Risk Assessment” were performed. The risk calculations rely on the
predictions of future sediment surface concentrations presented in Appendix D
“Empirical Mass Balance Model.” These predictions assume that active remediation
would be capable of generating a surface with concentrations at or below recontamination
levels, regardless of whether capping or dredging (with subsequent backfill or capping) is
implemented. Once active remediation of the surface sediments of the Area of Focus has
been completed, recontamination of the remediated surface would occur due to
deposition of contaminated sediment originating from contributing sources outside of the
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Area of Focus, while ongoing natural recovery processes would serve to reduce the
degree of contamination associated with these deposited solids.
The contributing sources of contaminated sediment include freshwater flow over Dundee
Dam, erosional areas located below the dam (outside of the Area of Focus), CSO/SWOs,
and tidal exchange with Newark Bay. All of these sources are assumed to follow the
observed rates of decline described in Appendix D “Empirical Mass Balance Model.”
There may be other inputs to the system but, based on the mass balance findings, such
inputs could contribute only minimally to future sediment concentrations, and thus to
post-remediation risk.
The recontamination processes modeled in Appendix D “Empirical Mass Balance
Model” are dependent on the deposition rate in the Area of Focus after remedial actions
are complete. The model relies on deposition rates ascertained from bathymetric surveys
conducted between 1989 and 2004 and estimates of exchange of solids between the Area
of Focus and each of the contributing sources. Deepening of the river in the Area of
Focus would likely increase the overall deposition rate in that area, and would also affect
the exchange between each of the contributing sources of solids loads and the Area of
Focus to some degree.
The engineered cap that would be placed in areas where significant inventory is to be
sequestered would be designed to withstand the erosive forces predicted by modeling in
those areas (see Appendix G “Cap Erosion and Flood Modeling”). Regular maintenance
would be required to sustain adequate coverage over the long term (possibly in
perpetuity), thereby reducing the likelihood of release. Backfill would only be placed in
those areas where all inventory has been targeted and only a minimal thickness of
contaminated fine-grained sediment due to dredging residuals remains after removal
activities are completed, and therefore any erosion of this backfill layer would result in
minimal potential for release. It should be noted that backfill layers would not be
monitored or maintained.
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The likelihood that contamination would be released from the CDF is considered
minimal. Significant industry experience associated with construction and maintenance
of CDFs exists, and the design and construction of a CDF would be conducted so as to
reduce the potential for future exposure. Excavation that may occur within the footprint
of the CDF to increase its capacity would need to be accomplished in low permeability
geologic strata or effectively lined with similar material.
Adequacy and Reliability of Controls: The adequacy and reliability of controls
associated with each alternative has been assessed by examination of the individual
process options employed.
Engineered caps, which include an armor layer in erosive areas, have been shown to be
adequate in achieving sequestration of contaminated sediment. The erosive areas which
are assumed for conceptual design purposes to require armor were determined using the
results of the hydrodynamic modeling presented in Appendix G “Cap Erosion and
Flooding Modeling.” The reliability of engineered caps depends upon proper design and
the consistency and sufficiency of future maintenance.
Placement of backfill material, which would not include armor and would not be
monitored or maintained, is not considered to be adequate or reliable in maintaining
sequestration. Since backfill would only be placed in those areas where minimal amounts
of contaminated fine-grained sediments remain after removal activities are complete, any
erosion would be of significantly diluted sediments.
Based on the evaluations presented in Section 4.2 “Selection of Representative Process
Options,” thermal treatment is a representative ex situ treatment process option selected
for detailed analysis. Thermal treatment has been shown to be effective in achieving
destruction and removal efficiencies of 99.9999 percent for organic contaminants.
Volatile metals can be effectively removed from flue gas with properly designed controls,
typically using activated carbon. Non-volatile metals are either sequestered in glass (for
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vitrification) or in the slag or ash produced during thermal destruction. Therefore, thermal
treatment is considered an adequate treatment technology.
Off-gas and particulate emissions from thermal treatment facilities are effectively
controlled to meet applicable standards by scrubbers and other pollution control devices.
Residuals from thermal treatment would be disposed in a secure landfill or CDF. Any
beneficial use product created by the thermal treatment process would be tested to verify
that it does not pose a risk to end users.
The use of a CDF for storage or final disposal, if constructed properly (e.g., with low
permeability barriers and effluent controls) is considered to be both adequate and reliable
based on the preliminary identification of potential sites and the use of similar facilities in
other projects. Design and construction of a CDF would be conducted in accordance
with USEPA guidance, including an assessment of contaminant migration pathways
(USEPA, 2005).
Long-term maintenance procedures would be required to ensure the reliability of the
remedy. An engineered cap would require inspection of the cap by bathymetric surveys
and maintenance of the cap by placement of additional material on a routine basis in
perpetuity. For the purposes of conceptual design an annual basis has been assumed, but
an increase in frequency after major storms could be considered, or conversely a decrease
in frequency after determining that the cap is suitably stable. In addition, long-term
institutional controls, as discussed in Section 4.2 “Selection of Representative Process
Options,” may be required to maintain the integrity of capped or backfilled areas. Fiveyear reviews would be incorporated to evaluate whether the remedy continues to be
adequate and reliable.
5.1.2.2
Reduction of Toxicity, Mobility, or Volume through Treatment
This criterion addresses the statutory preference for selecting remedial actions that
employ treatment technologies that permanently and significantly reduce toxicity,
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mobility, or volume of the hazardous substances. The evaluation focuses on the
following factors:
•
Treatment processes the remedy will employ and the materials they will treat.
•
The mass and volume of hazardous materials that will be treated.
•
The degree of expected reduction in toxicity, mobility, or volume.
•
The degree to which treatment will be irreversible.
•
The type and quantity of treatment residuals that will remain following treatment.
•
Whether the alternative would satisfy the statutory preference for treatment as a
principal element.
This criterion is evaluated both by the extent to which toxicity, mobility, and volume of
contaminated sediments are reduced within the Lower Passaic River, as well as the extent
to which toxicity, mobility, and volume of sediments are reduced based on the final
treatment or disposition of removed sediments.
The degree of volume reduction of the contaminated sediment varies based on the depth
and extent of dredging. The type of treatment specified for the dredged material dictates
the degree of reductions in toxicity, mobility, and volume. Thermal treatment would be
expected to achieve approximately 99.9999 percent reduction in organic contaminants.
Residuals from thermal treatment would be disposed in a secure landfill or CDF.
Thermal treatment would meet the statutory preference for treatment.
If dewatering and wastewater treatment were implemented, these processes would reduce
the toxicity, mobility, and volume of contaminants in process water, but would likely
generate treatment residuals such as flocculation sludge and filter sands. The quantities
of these treatment residuals would depend on the sediment volumes that are removed.
Storage or disposal of dredged material in a CDF would reduce the mobility of
contaminated material, and some volume reduction of the solid matrix (but not the
contaminants themselves) is possible with time, through consolidation of the placed
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dredged material. However, this approach would not reduce the toxicity of the dredged
material, and would not meet the statutory preference for treatment.
For capping, the mobility of contaminants in capped areas would be reduced because the
solids-bound contaminants would be sequestered under an engineered cap, thus reducing
the transport to Newark Bay and the New York-New Jersey Harbor Estuary.
Nevertheless, capping does not satisfy the CERCLA statutory preference for treatment.
There is no reduction in the toxicity or volume of the contaminants under the cap.
5.1.2.3
Short-Term Effectiveness
The short-term effectiveness criterion addresses the impacts of the remedial alternatives
during construction and implementation. The following factors are considered with
respect to this criterion:
•
Protection of the community during remedial actions.
•
Protection of workers during remedial actions.
•
Environmental impacts.
•
Time until remedial action objectives are achieved.
The approach for assessing each of these factors is summarized below.
Protection of the Community during Remedial Actions: Protection of the community
depends on the duration of construction and the potential for exposure to contamination
due to remedial activities. During construction, transfer facilities and treatment areas
present potential short-term risks to the community due to air emissions and noise.
Access to these areas would be restricted to authorized personnel, and an ambient air
monitoring program could be implemented where required. Work areas in the river
would be isolated (access-restricted) for safety reasons. In-river barge traffic associated
with the remedies would be monitored and controlled to minimize adverse effects on
commercial or recreational use of the river.
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Capping operations may be less disruptive of local communities than dredging (USEPA,
2005), and would result in less potential for noise disturbances and air pollution than
dredging operations. Since capping operations do not involve the same secondary
processes as dredging (i.e., dewatering, treatment, and/or transport or contaminated
sediment), the potential for exposure of the community to dredged material is expected to
be much lower than for dredging operations.
In the short term, risks to humans from consumption of fish and shellfish remain the
same, and existing fish advisories would continue to be enforced.
Protection of Workers during Remedial Actions: The implementation of any remedial
action would potentially expose workers to contaminated sediment, and the extent of
exposure depends heavily on project duration. However, dredging of contaminated
sediment would likely result in increased possibility of exposure via direct contact,
ingestion, and inhalation of contaminants in sediments and surface water. Workers will
be required to follow Occupational Safety and Health Administration (OSHA)
regulations and project-specific health and safety plans.
Environmental Impacts: The primary environmental impacts due to dredging operations
would include a temporary increase in suspended sediments concentrations, and
therefore, potentially a temporary increase in fish and shellfish tissue contaminant
concentrations. There will also be a temporary loss of habitat for aquatic and benthic
organisms. The degree of impact is directly related to the area remediated and volume
dredged. These impacts will be mitigated by the use of environmental dredging
techniques and best management practices that minimize resuspension.
Backfilling will be implemented to mitigate impacts to aquatic and benthic organisms,
and a biological monitoring program will be implemented to verify the attainment of
objectives for aquatic and benthic life and habitat replacement.
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Activities associated with capping and CDF construction would also result in a temporary
loss of habitat for aquatic and benthic organisms. Environmental impacts during capping
would be mitigated by using cap placement techniques that avoid resuspension to the
extent practicable.
Time Until Remedial Action Objectives are Achieved: The time until RAOs are
achieved depends on the duration of several project components, including pre-design
investigation, design, mobilization, dredging, backfilling and/or capping, reconstruction,
and demobilization. In addition, following implementation, an equilibration period
followed by a period of natural recovery would likely be required to achieve RAOs.
The comprehensive 17-mile Study will evaluate remaining threats to human health and
the environment in the Study Area and the timeframe to achieve RAOs through a fate,
transport, and bioaccumulation model that is currently in development and not available
for the FFS.
5.1.2.4
Implementability
This criterion addresses the technical and administrative feasibility of implementing the
remedial alternatives. Implementability is evaluated based on the following factors:
•
Technical Feasibility.
•
Degree of difficulty associated with construction and operating the technology.
─ Reliability of the technology.
─ Ease of undertaking additional remedial actions, if necessary.
─ Ability to monitor the effectiveness of the remedy.
•
Administrative feasibility.
─ Coordination with other agencies.
─ Ability to obtain approvals from other agencies.
•
Availability of services and materials.
─ Availability of necessary equipment and specialists.
─ Availability of adequate treatment, storage capacity, and disposal services.
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─ Availability of prospective technologies.
─ Availability of services and materials, plus the potential for obtaining competitive
bids.
The approach for assessing each of these factors in relation to the process options which
comprise the remedial alternatives is summarized below.
Technical Feasibility: Sediment removal via mechanical dredges is a common and
available technology. The technology was shown to be feasible during the Dredging and
Decontamination Pilot Study (Thompson et al., 2006) performed in the Lower Passaic
River in December 2005. However, technical difficulties that may be associated with
dredging operations include shoreline protection, utility protection, resuspension of
sediment, and management of dredging residuals. It is anticipated that engineering
controls and data could be used to address these issues.
Implementation of an active remedial action would require obtaining adequate land space
to construct transfer and processing facilities. A processing location would require wharf
facilities and sufficient acreage to accommodate the needs of the project. Preliminary
siting studies conducted by NJDEP and summarized in Appendix H “Dredged Material
Management Assessments” identify a sufficient number of potentially acceptable
properties to assume that a siting process conducted during a design phase could select a
viable site. It should be noted that other sediment remediation projects have successfully
sited transfer and processing facilities despite similarly challenging environments.
The reliability of secondary processes associated with dredging (e.g., sediment
dewatering, transport, treatment, beneficial use, and/or disposal) could impact the
technical feasibility of the remedy. For instance, operational problems with dewatering
equipment (e.g., clogging of filters) could slow dredging operations. The use of CDF
capacity for disposal or storage could reduce the project’s dependence on these secondary
processes.
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Capping of contaminated sediments is typically accomplished with commonly available
or easily adapted equipment. Technical difficulties pertaining to capping operations
include locating a suitable borrow source for cap material (refer to “Availability of
Services and Materials” below), ensuring that the cap materials are applied in a manner
that produces a continuous layer that achieves the desired cap thickness and erosion
protection, and ensuring that additional flooding would not be caused due to changes in
bathymetry or bottom roughness. Implementation of capping would increase the cost of
future remedial dredging operations, but would not preclude their implementation.
Administrative Feasibility: Remedial actions would have to be performed in accordance
with ARARs. Restrictions on remediation activities, if placed by trustee agencies (e.g.,
fish windows), could result in longer project durations, or require additional equipment
for schedule purposes. For purposes of this analysis, it has been assumed that dredging
restrictions (fish windows) would be waived.
If the Lower Passaic River navigation channel were to be de-authorized or the authorized
depth changed prior to cap placement, this de-authorization or change in authorized depth
would require approval by an act of Congress with concurrence by the State of New
Jersey. Cap placement would require long-term site access restrictions to ensure no
disturbances of the cap by passing vessels, channel maintenance, or other potential
disturbances.
Availability of Services and Materials: Dredging and capping are both well developed
technologies, and procurement of adequate, reliable, and available technology should not
present a significant challenge to implementability.
Initial efforts have identified several potential land-based borrow sources in New Jersey
collectively capable of supplying suitable capping material; however, the capacity of
individual sources has not been determined. Additionally, under the New York Harbor
Deepening Program, several million cubic yards of sand will be removed from federal
navigation channels between 2008 and 2011; although modeling results presented in
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Appendix G “Cap Erosion and Flood Modeling” show that a cap cannot be constructed of
this sand alone, this sand could be suitable for use in a filter layer or as backfill material.
Furthermore, substantial quantities of rock will be removed from federal navigation
channels, and could, if processed, be used as armor material. Significant cost savings
would be realized if remediation activities could be coordinated with regional dredging
programs (e.g., utilization of sand or rock from the Harbor Deepening Program) to
beneficially use this dredged material for backfill of dredged areas or construction of an
engineered cap.
A preliminary review of the environs of the Lower Passaic River and Newark Bay
suggests there are various nearshore areas amenable to the development of a CDF of
sufficient size to accommodate the material to be removed from the Lower Passaic River
as a consequence of any alternative. A thorough siting study would be required during
the design phase to select an appropriate location.
Some portion of the contaminated sediment in the Lower Passaic River could be treated
via thermal destruction methods. This feasibility analysis has identified potential thermal
treatment options and vendors, and has identified no technical issues that would prevent
construction of a new onsite facility.
5.1.2.5
Cost
Costs for CERCLA evaluations are divided into two principal categories: capital costs
and annual O&M costs. Consistent with the RI/FS guidance (USEPA, 1988), cost
estimates performed during the feasibility study stage are expected to provide an
accuracy of -30 percent to + 50 percent. Capital costs and O&M costs have been
estimated for all of the active remedial alternatives. Cost tables and a summary of major
cost assumptions are provided in Appendix J “Cost Estimates.”
Capital Costs: Capital cost items include activities pertaining to pre-construction
investigations and design, mobilization/demobilization, site preparation, dredging and/or
capping, and dredged material management. Unit prices for capital cost items were based
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on estimates from vendors and contractors, cost estimates from projects involving similar
activities, and engineering judgment. In addition, an allowance for construction
management of 7 percent of the capital costs, a fee of 10 percent of the capital costs, and
a contingency allowance of 20 percent of the capital costs have been incorporated into the
cost estimate.
O&M Costs: O&M costs for the active alternatives include activities such as bathymetric
surveys, sediment and water column sampling, biota monitoring, and cap monitoring and
maintenance. As for the capital costs, unit costs for O&M activities were based on
estimates from vendors and contractors, cost estimates from projects involving similar
activities, and engineering judgment. The cost estimates generated for this analysis are
based on an O&M period of 30 years. However, a longer timeframe may apply for cap
maintenance (e.g., in perpetuity).
Present Worth Analysis: In order to compare costs for alternatives that have different
implementation time frames, the present worth for each alternative was calculated. Costs
are presented in 2006 dollars. A discount rate of 5 percent is used for the present worth
calculation. The present worth of annual O&M activities was calculated for an assumed
duration of 30 years.
5.1.3
5.1.3.1
Modifying Criteria
State Acceptance
This criterion provides the state – in this case, the State of New Jersey – with the
opportunity to assess any technical or administrative issues and concerns regarding each
of the alternatives. State acceptance is not addressed in this document, but will be
addressed in the ROD. It is important to note that NJDOT is the WRDA non-federal
sponsor and NJDEP is a Trustee for the Site; both are agency partners participating in the
Study. As such, input from the State of New Jersey was sought and considered
throughout the development of the FFS.
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5.1.3.2
Community Acceptance
Issues and concerns the public may have regarding each of the alternatives fall into this
criterion. As with state acceptance, this criterion will be addressed in the ROD once
comments on the FFS and proposed plan have been received. Input from the public and
interested stakeholders, including the Cooperating Parties, was sought and considered
throughout development of the FFS. This occurred through various technical Workgroup
sessions organized and hosted by USEPA, through publication of information on the
project website www.ourpassaic.org, publication of information to interested members of
the public in the form of ListServ notices, and other Community Involvement activities.
5.2
ANALYSIS OF ALTERNATIVES
The detailed analysis of the individual alternatives with respect to the criteria discussed
above is presented in Table 5-1 (attached). This section presents a comparison among
alternatives and analyzes trade-offs to be considered for each criterion.
5.2.1
Overall Protection of Human Health and the Environment
Based on the risk evaluations summarized in Section 2.6 “Risk Reduction Resulting from
Remediation of Identified Target Areas” and presented in full in Appendix C “Risk
Assessment,” existing conditions present unacceptable risks to human health and the
environment. Active remediation of the Area of Focus reduces the COPC and COPEC
concentrations in the surface sediments to within the background concentrations that are
currently introduced to the Lower Passaic River from the Upper Passaic River, reduces
the human health risk by 95 to 98 percent (fish versus crab consumption), and reduces the
ecological hazard by 78 to 98 percent (species dependent) (refer to Section 2.6 “Risk
Reduction Resulting from Remediation of Identified Target Areas”), which meets the
RAO. Based on prediction of future surface concentrations generated using the
Empirical Mass Balance Model (Appendix D), active remediation of the Area of Focus
followed by MNR will achieve any threshold for 2,3,7,8-TCDD, which is responsible for
about 65 percent of the risk, 40 years faster than it would be achieved by the No Action
alternative. The reduction of other COPCs and COPECs is also accelerated by active
remediation of the Area of Focus (refer to Section 2.7 “Selection of Target Area for
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Remediation”). For this reason, the six active alternatives are considered more protective
of human health and the environment than the No Action alternative.
The 17-mile Study will evaluate remaining threats to human health and the environment
in the Study Area and the timeframe to achieve RAOs using a fate, transport, and
bioaccumulation model that is currently in development and not available for the FFS.
5.2.2 Compliance with ARARs
None of the identified action-specific or location-specific ARARs are applicable to the
No Action alternative. Each active alternative, if implemented, would be designed and
constructed in compliance with the ARARs identified, except those which may be waived
by the Regional Administrator in accordance with CERCLA Section 121(d).
The active alternatives are comprised of seven elements, as described in Section 5.1.1.2
“Compliance with ARARs.” Table 5-2 lists the ARARs and their statutory or regulatory
citations for each of these seven elements. This table also presents the rationale for the
parts of each element of the remediation process that will fall under each ARAR.
5.2.3
5.2.3.1
Long Term Effectiveness and Permanence
Magnitude of Residual Risk
The overall risk reduction achieved by each alternative has been evaluated based on the
future surface concentrations predicted by the Empirical Mass Balance Model (refer to
Appendix D “Empirical Mass Balance Model”). Over the time frame considered (30
years after remedial actions are complete), the six alternatives which use active remedial
measures reduce cancer risk for the combined child/adult receptor to 5 × 10-4 from fish
consumption and to 4 × 10-4 from crab consumption. In addition, the non-cancer health
HI for the adult receptor is reduced from 64 to 4.7 from fish consumption and from 86 to
3.5 from crab consumption (see Table 2-11). The non-cancer health HI for the child
receptor is reduced from 99 to 22 from fish consumption and from 140 to 19 from crab
consumption. The ecological hazards present at the site are reduced from 339 to 5.8 for
the mink receptor and from 49 to 1.8 for the heron receptor. The risk reduction for each
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of the six active alternatives is equivalent at the level of precision achieved by the
calculations presented in Appendix D “Empirical Mass Balance Model,” and no
additional risk reduction is estimated to result from additional removal of contaminated
sediment, as each alternative places a sand layer and achieves equivalent surface
concentrations following active remediation. In addition, all of the active remedial
alternatives rely on institutional controls to maintain protectiveness following remedy
construction, while natural recovery processes continue to reduce surface concentrations
in the Area of Focus to reduce risks to within the risk range. Also, separate source
control actions above Dundee Dam, when implemented, will accelerate the time frame
within which the active alternatives achieve risk ranges.
The No Action alternative does not achieve the reductions in risk described above for the
active alternatives. Over the time frame considered (30 years after the active components
of remedial alternatives are complete), the natural recovery processes in the No Action
alternative only reduce cancer risk for the combined child/adult receptor to 4 × 10-3 from
fish consumption and to 3 × 10-3 from crab consumption; these levels are still well
outside EPA’s acceptable risk range. In addition, the non-cancer health HI for the adult
receptor is reduced from 64 to 6.8 from fish consumption and from 86 to 5.2 from crab
consumption. The non-cancer health HI for the child receptor is only reduced from 99 to
31 from fish consumption and from 140 to 27 from crab consumption. The ecological
hazards present at the site are reduced from 339 to 52.4 for the mink receptor and from
49 to 5.2 for the heron receptor. These reductions are less than for the active alternatives
It should be noted that the risk reduction observed from the No Action alternative is due
to natural recovery processes, among which a dominant mechanism is likely the dilution
of contaminated sediments in the Area of Focus due to exchange with other contributing
sources of solids load. This dilution likely results in transfer of contaminated sediments
from the Area of Focus to Newark Bay and the New York-New Jersey Harbor Estuary.
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5.2.3.2
Adequacy and Reliability of Controls
The No Action alternative does not provide for engineering controls on the river
sediments. Among the active alternatives, there is not a great difference in the degree of
adequacy of controls achieved. The reliability of both dredging and engineered caps
depends upon proper design and implementation, while the reliability of capping also
depends on the consistency and sufficiency of future maintenance.
Alternative 1 relies exclusively on placement of a backfill layer to provide a measure of
control in the event that residual contamination poses health risks. This alternative does
not include an engineered cap, because the intent is for the contaminated fine-grained
sediment to be removed with the assumption that the underlying less-contaminated sand
material will not erode to any significant extent. The backfill layer is not intended to be
maintained, in contrast to the engineered cap in Alternative 2 whose thickness is
maintained in the long term in order to ensure protectiveness of contaminant inventory
left underneath.
Alternatives 3, 4, 5, and 6 rely on varying combinations of backfill and engineered cap,
depending on the amount of contaminated inventory left after dredging. Of these four
alternatives, Alternative 3 proposes removing the most fine-grained sediment down to the
underlying sandy layer, while Alternative 4 proposes leaving behind the most
contaminant inventory, so that Alternative 3 relies most heavily on backfill and
Alternative 4 relies most on engineered capping. Institutional controls would be required
to ensure that engineered cap layers are not disturbed by human activities.
In all active alternatives, the use of a CDF for storage or final disposal, if constructed
properly (e.g., with low permeability barriers and with effluent controls) is considered to
be adequate and reliable based on the preliminary identification of potential sites and the
use of similar facilities in other projects.
Established thermal destruction facilities have sufficient prior experience with treatment
of hazardous materials and disposal of treatment residuals to predict a high level of
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reliability. Newly constructed facilities would require a prove-out period to demonstrate
ability to reduce contaminant concentrations resulting from implementation of any active
alternative to acceptable levels reliably and to ensure air emissions are within acceptable
ranges.
5.2.4
Reduction of Toxicity, Mobility, and Volume through Treatment
5.2.4.1
Treatment Processes Used and Materials Treated
The No Action alternative does not involve any containment or removal of contaminants
from the Lower Passaic River sediments. Among the active alternatives (Alternatives 16), the treatment processes used do not vary.
The extent to which each treatment process is used varies based on the mass and volume
of sediment removal. For example, Alternative 2 removes the least amount of sediment,
while Alternative 1 removes the most. After removal, thermal treatment of dredged
sediment, if used, will irreversibly destroy organic contaminants in the treated sediment,
while non-volatile metals will be fused and bound into the residual matrix. Volatile
metals will be released from the sediment matrix and captured during control of the offgas emissions. In addition, water treatment process associated with dewatering
operations will reduce the toxicity, mobility, and volume of contaminants present in
process water.
5.2.4.2
Amount of Hazardous Material Destroyed or Treated
The No Action alternative does not involve any destruction or treatment of contaminants
from the Lower Passaic River sediments. Among the active alternatives, the amount of
contaminated sediment removed and treated varies based on the depth and extent of
dredging. The estimates of removal volume are presented in Table 5-1.
5.2.4.3
Degree of Expected Reductions in Toxicity, Mobility, and Volume
The No Action alternative results in minimal reduction in toxicity, mobility, and volume
by natural recovery processes. It should be noted that any reductions observed from the
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No Action alternative is due to natural recovery processes, among which a dominant
mechanism is likely the dilution of contaminated sediments in the Area of Focus due to
exchange with other contributing sources of solids load. This dilution likely results in
transfer of contaminated sediments from the Area of Focus to Newark Bay and the New
York-New Jersey Harbor Estuary.
The six active alternatives vary slightly in their expected degrees of reduction.
Alternative 1 involves removal of all fine-grained sediment. Alternatives 2-6 involve
some removal of sediments before placement of a cap and armor. Each of these
alternatives would, to some degree, reduce the volume of contaminated sediment in the
Lower Passaic River by removal and subsequent treatment, if dredged material
management Scenario B were selected. The degree of volume reduction varies based on
the depth and extent of dredging. The type of treatment specified for the removed
sediment dictates the degree of reductions in toxicity, mobility, and volume. Thermal
treatment would be expected to achieve approximately 99.9999 percent reduction in
organic contaminants. Thermal treatment residuals could be disposed in a secure landfill
or CDF. Material disposed in a CDF would not be treated prior to placement, but the
mobility of contaminants in the material would be reduced. Disposal in a CDF would not
satisfy the CERCLA statutory preference for treatment.
Alternatives 2-6 rely on capping to sequester contaminated sediments. The cap reduces
the mobility of contaminants, thus reducing the transport to Newark Bay and the New
York-New Jersey Harbor Estuary. Capping does not satisfy the CERCLA statutory
preference for treatment. In addition, there is no reduction in the toxicity or volume of
the contaminants under the cap.
5.2.4.4
Type and Quantity of Residuals Remaining after Treatment
The No Action alternative generates no residuals. The active alternatives vary in the
quantity of residuals generated based on the degree of sediment removal.
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If sediment removal is followed by dewatering and water treatment, residuals such as
flocculation sludge and filter sands would be generated. The quantities of these residuals
would depend upon the sediment volumes that are removed. In addition, alternatives
involving sediment dewatering may generate debris such as rocks, wood, and a variety of
navigational and urban refuse that would be unable to pass through the dewatering
treatment train; these materials would need to be managed as waste or recycled.
Thermal destruction would irreversibly destroy contaminants in the treated sediment.
Thermal treatment residuals could be disposed in a secure landfill or CDF or be used
beneficially as a product.
5.2.5 Short Term Effectiveness
No construction activities are associated with the remediation of sediments for the No
Action alternative, so it does not increase the potential for direct contact or ingestion of
contaminants from the sediments beyond current levels. The active alternatives vary
slightly in short term effectiveness, as discussed below.
5.2.5.1
Protection of the Community during Remedial Actions
Implementation of any active remediation alternative would result in impacts to the
community (e.g., noise, lights, and traffic) and could potentially require the processing,
storage, transportation, and disposal of contaminated sediment near the Lower Passaic
River. Engineering controls would be in place to reduce the potential for exposure of the
community to contaminants.
The placement of cap materials would likely result in a lesser degree of resuspension than
dredging of contaminated sediment (USEPA, 2005). The overall duration during which
the community would be impacted is greater for alternatives which remove a greater
volume of material (e.g., Alternative 1 would impact the community for a longer period
of time than Alternative 2).
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5.2.5.2
Protection of Workers during Remedial Action
The implementation of any active remediation alternative would potentially expose
workers to contaminated sediment; however, dredging activities could result in a higher
likelihood of exposure via direct contact, ingestion, and inhalation of contaminants in
sediments and surface water than would placement of capping materials. The overall
time during which workers would require protection is greater for alternatives which
remove a greater volume of material.
5.2.5.3
Environmental Impacts
Alternatives which involve dredging of larger quantities of material require longer project
durations, and potentially present incrementally greater potential for increased exposure
of the community to dredged material. This potential for exposure can be reduced with
the proper engineering controls, health and safety approaches, and design considerations.
In addition, the short term environmental impacts associated with resuspension of
contaminated sediment would likely be incrementally greater for alternatives involving
greater volumes of removal.
The existing habitat present in the Area of Focus would be impacted by any active
remediation alternative. In addition, resuspension associated with cap placement or
dredging activities could result in the transport of contaminated sediments and
subsequent impact to adjacent areas. The placement of cap materials would likely result
in a lesser degree of contaminant resuspension than dredging of contaminated sediment.
All active alternatives would involve the placement of clean material over existing
sediment and reconstruction of mudflat areas impacted by remedial activities. In areas
where armor is placed, benthic recolonization could occur, provided that silt or other
benthic habitat material is subsequently deposited via natural processes. The construction
of a CDF would constitute a permanent impact to habitat, and would require mitigation.
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5.2.5.4
Time until Remedial Action Objectives are Achieved
The six active alternatives vary slightly in duration of implementation, as each alternative
contains similar components including pre-design activities, design, mobilization,
dredging, capping or backfilling, and demobilization. Following implementation, trends
in surface sediment concentrations for each alternative are also comparable, as the postimplementation surface sediment concentrations achieved by each alternative are
equivalent. These trends may be influenced by the depositional conditions achieved by
each alternative, as discussed in Section 5.1.2.1 “Long-Term Effectiveness and
Permanence.”
The 17-mile Study will evaluate remaining threats to human health and the environment
in the Study Area and the timeframe to achieve RAOs through a fate, transport, and
bioaccumulation model that is currently in development and not available for the FFS.
5.2.6
5.2.6.1
Implementability
Technical Feasibility
The No Action alternative and Alternatives 1-6 are all technically feasible. However, a
major consideration in evaluating the feasibility of each alternative after implementation
is the impact on flooding caused by changes in the bathymetry and bottom roughness of
the river. The No Action alternative would likely result in a gradual increase in flooding
impacts due to continued accumulation of sediments; however this has not been
confirmed by modeling. Hydrodynamic modeling results presented in Appendix G “Cap
Erosion and Flood Modeling” indicate that Alternatives 2 and 4 have considerable
flooding impacts; implementation of either alternative would increase flooding by 93 and
24 acres respectively beyond the amount predicted by modeling of existing conditions.
Conversely, implementation of Alternative 5 would result in a slight reduction (by 17
acres) in flooding impact compared to existing conditions. Alternatives 1, 3, and 6 were
not modeled, but are expected to show reductions similar to or greater than those
predicted by modeling of Alternative 5, as similar sediment surface conditions but greater
water depths are achieved by implementation of these alternatives.
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5.2.6.2
Availability of Services and Materials
Each active alternative utilizes both dredging and capping or backfilling. Dredging and
capping are both well developed technologies, and adequate, reliable, and available
technology can be procured; there are no anticipated challenges to implementability.
Initial efforts have identified several potential land-based borrow sources in New Jersey
collectively capable of supplying suitable capping material for the implementation of
active alternatives; however, the capacity of individual sources has not been determined.
Additionally, under the New York Harbor Deepening Program, several million cubic
yards of sand will be removed from federal navigation channels between 2008 and 2011;
although modeling results presented in Appendix G “Cap Erosion and Flood Modeling”
show that a cap cannot be constructed of this sand alone, this sand could be suitable for
use in a filter layer or as backfill material. Furthermore, substantial quantities of rock
will be removed from federal navigation channels, and could, if processed, be used as
armor material. Significant cost savings would be realized if remediation activities could
be coordinated with regional dredging programs (e.g., utilization of sand or rock from the
Harbor Deepening Program) to beneficially use this dredged material for backfill of
dredged areas or construction of an engineered cap.
A preliminary review of the environs of the Lower Passaic River and Newark Bay
suggests there are various nearshore areas amenable to the development of a CDF of
sufficient size to accommodate the material to be removed from the Lower Passaic River
as a consequence of any alternative. A thorough siting study would be required during
the design phase.
Some portion of the contaminated sediment in the Lower Passaic River could be treated
via thermal destruction methods. This feasibility analysis has identified potential thermal
treatment options and vendors, and has identified no technical issues that would prevent
construction of a new onsite facility.
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5.2.6.3
Administrative Feasibility
The execution of any remedial activity in the Lower Passaic River would require
significant coordination with and among federal, state, and local agencies. Alternatives
2-6, those involving capping, would require that issues pertaining to navigation be
resolved prior to design of cap elevation, and that the creation of future habitat be
discussed. Alternatives which incorporate greater quantities of dredging could
potentially require incrementally more coordination due to the greater impact that
dredged material management activities would have on the surrounding area and the need
to identify suitable locations for a CDF for processing, storage, transportation, treatment,
and disposal of dredged material.
5.2.7
Cost
The total cost for each alternative has been estimated based on capital costs as well as
O&M costs, and is presented in Appendix J “Cost Estimates.” The active alternatives
range in cost from $0.9 billion to $2.3 billion.
5.2.7.1
Capital Costs
Capital costs have been estimated for activities pertaining to pre-construction
investigations and design, mobilization/demobilization, site preparation, dredging and/or
capping, and dredged material management. While capital costs for these activities vary
predictably based on the extent of remediation conducted, the major drivers of capital
cost are dredging and dredged material management. Alternatives which utilize dredging
to remove a given volume of contaminated sediment are significantly more costly than
alternatives which sequester the same volume of contaminated sediment by means of an
engineered cap.
5.2.7.2
Operations and Maintenance Costs
Alternatives which employ an engineered cap over a greater area require more significant
operations and maintenance costs. Monitoring of cap thickness and replenishment could
be required, to some extent, in perpetuity. The extent of monitoring and maintenance,
and therefore the total present worth of O&M costs, would depend on the time needed to
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verify the long term stability of the cap and the absence of significant contaminant fluxes
through the cap. The cost estimates generated during this feasibility analysis have been
based on a maintenance period of thirty years; however, a longer timeframe may apply
for cap maintenance.
Finally, while operations and maintenance costs are higher for alternatives which utilize
an engineered cap, the capital costs associated with dredged material management drive
the total cost of alternatives which involve greater quantities of dredging. Alternatives
involving capping achieve the same mass remediation and risk reduction as alternatives
involving greater quantities of dredging for significantly lower total cost; however, the
reliability of capping depends on the consistency and sufficiency of future maintenance
activities.
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6.0
ACRONYMS
ºF
Degrees Fahrenheit
2,3,7,8-TCDD
2,3,7,8-Tetrachlorodibenzo-p-dioxin
AhR
Aryl Hydrocarbon Receptor
Alt.
Alternative
ARARs
Applicable or Relevant and Appropriate Requirements
ARCS
Assessment and Remediation of Contaminated Sediments
BAF
Bioaccumulation Factor
CAD
Contained Aquatic Disposal
CASRN
Chemical Abstracts Service Registry Number
CBR
Critical Body Residues
CDF
Confined Disposal Facility
CERCLA
Comprehensive Environmental Response, Compensation, and
Liability Act
CFR
Code of Federal Regulations
COPC
Contaminant of Potential Concern
COPEC
Contaminant of Potential Ecological Concern
CPT
Cone Penetrometer Testing
CRREL
Cold Regions Research and Engineering Laboratory
CSM
Conceptual Site Model
CSO
Combined Sewer Overflow
CWA
Clean Water Act
D50
Median Stone Size
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DDD
Dichlorodiphenyldichloroethane
DDE
Dichlorodiphenyldichloroethylene
DDT
Dichlorodiphenyltrichloroethane
DDx
Sum of DDD, DDE, and DDT isomers
D/F
Dioxins/Furans
DOER
Dredging Operations and Environmental Research
DQO
Data Quality Objective
EPC
Exposure Point Concentration
ERA
Ecological Risk Assessment
ER-L
Effects Range-Low
FFS
Focused Feasibility Study
FRTR
Federal Remediation Technologies Roundtable
HHRA
Human Health Risk Assessment
HI
Hazard Index
HPAH
High Molecular Weight PAH
HSWA
Hazardous and Solid Waste Amendments
H:V
Horizontal:Vertical
IDW
Investigation Derived Waste
LDR
Land Disposal Regulation
LOAEL
Lowest Observed Adverse Effect Level
LPAH
Low Molecular Weight PAH
mg/kg
milligrams per kilogram of sediment
MLW
Mean Low Water
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MNR
Monitored Natural Recovery
MPA
Mass Per Unit Area
NBSA
Newark Bay Study Area
NCP
National Contingency Plan
ND
Not Determined
ng/g
nanograms per gram of sediment
ng/kg
nanograms per kilogram of sediment
N.J.A.C.
New Jersey Administrative Code
NJDEP
New Jersey Department of Environmental Protection
NJDOT
New Jersey Department of Transportation
NJDOT-OMR
New Jersey Department of Transportation, Office of Maritime
Resources
NJPDES
New Jersey Pollutant Discharge Elimination System
N.J.S.A.
New Jersey Statutes Annotated
NOAA
National Oceanic and Atmospheric Administration
NOAEL
No Observed Adverse Effect Levels
O&M
Operations and Maintenance
OENJ
Orion of Elizabeth New Jersey
OSHA
Occupational Safety and Health Administration
OSWER
Office of Solid Waste and Emergency Response
PaDEP
Pennsylvania Department of Environmental Protection
PAH
Polycyclic Aromatic Hydrocarbons
PCB
Polychlorinated Biphenyls
PCDD/F
Polychlorinated Dioxins/Furans
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POTW
Publicly Owned Treatment Works
ppt
parts per trillion
PRG
Preliminary Remedial Goal
RAGS
Risk Assessment Guidance for Superfund
RAO
Remedial Action Objective
RBC
Risk-Based Concentration
RCRA
Resource Conservation and Recovery Act
RI
Remedial Investigation
RI/FS
Remedial Investigation/Feasibility Study
RM
River Mile
RME
Reasonably Maximum Exposure
ROD
Record of Decision
SARA
Superfund Amendments and Reauthorization Act
SPI
Sediment Profile Imaging
SWO
Stormwater Outfall
Tb
Thickness for Bioturbation
TBC
To Be Considered
Tc
Thickness for Consolidation
TCLP
Toxicity Characteristic Leaching Procedure
Te
Thickness for Erosion
TEQ
Toxic Equivalency Quotient
Ti
Thickness for Chemical Isolation
Ts
Thickness for Settlement
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TSCA
Toxic Substances and Control Act
UCL
Upper Confidence Limit
μg/kg
micrograms per kilogram of sediment
U.S.C.
United States Code
USACE
United States Army Corps of Engineers
USEPA
United States Environmental Protection Agency
USFWS
United States Fish and Wildlife Services
VOC
Volatile Organic Compound
WRDA
Water Resources Development Act
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7.0
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